- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011