-11- groundless. We have repeatedly indicated our willingness to impose such penalties in collection review cases. Roberts v. Commissioner, supra. In Pierson v. Commissioner, 115 T.C. 576 (2000), taxpayers advancing frivolous and groundless claims and instituting proceedings under section 6330(d) for the purposes of delay were given unequivocal warning that the Court would impose penalties. See also Hoffman v. Commissioner, T.C. Memo. 2000- 198. Moreover, we have imposed penalties in such proceedings when the underlying tax liability was not at issue and the taxpayer raised frivolous and groundless arguments as to the legality of the Federal tax laws. Yacksyzn v. Commissioner, supra; Watson v. Commissioner, T.C. Memo. 2001-213; Davis v. Commissioner, T.C. Memo. 2001-87. Petitioner is a frequent litigator of groundless challenges to the validity of the Internal Revenue Code. See, e.g., Standifird v. United States, 41 Fed. Appx. 99 (9th Cir. 2002); Standifird v. Augustine, 74 AFTR 2d 94-5447, 94-2 USTC par. 50,530 (D. Ariz. 1994); Standifird v. United States, 32 Fed. Cl. 731 (1995). In a prior proceeding, this Court imposed upon petitioner a penalty under section 6673 of $2,500. Standifird v. Commissioner, T.C. Memo. 1995-348. Petitioner, however, continues to advance the same type of frivolous and groundless arguments as in the previous cases.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011