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been rejected by the U.S. Court of Appeals for the Ninth Circuit,
the court to which this case is appealable. The Court further
advised petitioner that he was wasting the Court’s time with his
frivolous arguments.
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we
issued an unequivocal warning to taxpayers concerning the
imposition of penalties pursuant to section 6673(a) on those
taxpayers who abuse the protections afforded by sections 6320 and
6330 by instituting or maintaining actions under those sections
primarily for delay or by taking frivolous or groundless
positions in such actions. Petitioner filed voluminous frivolous
documents and motions with the Court. Furthermore, the Court
warned petitioner that he was wasting the Court’s time.
Petitioner’s position, based on stale and meritless contentions,
is manifestly frivolous and groundless, and he has wasted the
time and resources of this Court. We are convinced that
petitioner instituted and maintained these proceedings primarily
for delay. Accordingly, we shall impose a penalty of $25,000
pursuant to section 6673.
To reflect the foregoing,
An appropriate decision
will be entered.
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Last modified: May 25, 2011