-12- Petitioner, we believe, has instituted and maintained this proceeding primarily for delay. His attention has been directed to our decision in Davis v. Commissioner, supra, wherein the Court imposed upon the taxpayer a $4,000 penalty under section 6673, for advancing frivolous and groundless claims. Pursuant to section 6673, we require petitioner to pay to the United States a penalty of $7,500. We have considered all arguments made by the parties and have found those arguments not discussed herein as irrelevant and/or without merit. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011