- 8 - Commissioner, supra. On this record, the Court sustains respondent on the section 6662(a) accuracy-related penalties for the 3 years at issue. Section 6673(a) authorizes the Court to require a taxpayer to pay to the United States a penalty not exceeding $25,000 when, in the Court's judgment, proceedings have been instituted or maintained by the taxpayer primarily for delay or where the taxpayer's position in the proceeding is frivolous or groundless. Although petitioners conceded the deficiencies and challenged only the penalties under section 6662(a), the Court considers petitioners' claim that they should not be liable for the penalties to be frivolous and groundless. Petitioners knew that a substantial portion of the itemized deductions at issue was false and could not be sustained. Other circumstances noted above need not be repeated here. The function of this Court is to provide a forum to decide issues relating to liability for Federal taxes. At trial, petitioners realized that they had no case with respect to the deficiencies but chose to continue to challenge the imposition of the penalties under section 6662(a). Any reasonable and prudent person, under the facts presented to the Court, should have known that the claimed deductions could not be sustained, and petitioners knew that. We do not and should not countenance the use of this Court as a vehicle for disgruntled litigants toPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011