- 15 -
primarily for delay or that the taxpayer's position in such
proceeding is frivolous or groundless. The Court has indicated
its willingness to impose such penalties in collection review
cases. Pierson v. Commissioner, 115 T.C. 576 (2000). Although
we shall not impose a penalty on petitioner pursuant to section
6673(a)(1) in the present case, we admonish petitioner that the
Court will consider imposing such a penalty should he return to
the Court in the future and advance arguments similar to those
that we have identified as frivolous.
To reflect the foregoing,
An order granting respondent’s
motion for summary judgment, as
supplemented, and decision will
be entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011