- 18 - having to deal with this matter wasted the Court's time, as well as respondent's, and taxpayers with genuine controversies may have been delayed. Also relevant is the fact that petitioners are, or should be, well aware of the provisions of section 6673. After all, at the administrative conference on August 21, 2001, the Appeals officer advised petitioners that they were advancing frivolous arguments; he provided them with a copy of this Court’s opinion in Pierson v. Commissioner, 115 T.C. 576 (2000), and he referred them to this Court’s opinion in Davis v. Commissioner, T.C. Memo. 2001-87 (imposing a penalty in the amount of $4,000). Under the circumstances, we shall grant respondent’s oral motion for the imposition of a penalty in that we shall impose a penalty on petitioners pursuant to section 6673(a)(1) in the amount of $1,000. In order to give effect to the foregoing, An appropriate order granting respondent's motions and decision for respondent will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011