Michael White - Page 10

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          the obvious reservations petitioner had at the time the returns             
          were prepared, he, nevertheless, failed to ascertain from tax               
          professionals whether his returns were correctly prepared.  These           
          facts demonstrate to the Court that petitioner made no reasonable           
          effort to ascertain his correct tax liability for the years at              
          issue.  Stubblefield v. Commissioner, supra.  On this record, the           
          Court sustains respondent on the section 6662(a) accuracy-related           
          penalties for the 2 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 petitioner conceded the deficiencies and challenged only           
          the penalties under section 6662(a), the Court considers                    
          petitioner's claim that he should not be liable for the penalties           
          to be frivolous and groundless.  Petitioner 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,                  
          petitioner realized that he had no case with respect to the                 
          deficiencies but chose to continue to challenge the imposition of           

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