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(C) the taxpayer unreasonably failed to
pursue available administrative remedies,
the Tax Court, in its decision, may require the
taxpayer to pay to the United States a penalty not
in excess of $25,000.
Petitioner had actual notice by the District Court order and
in this case that his arguments that his wages were not taxable
income were without merit. The various arguments that he made in
this case have been long discredited and patently were asserted
for purposes of delay. We conclude that a penalty under section
6673(a) should be awarded to the United States in the amount of
$10,000.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011