- 9 - Under these circumstances we are convinced and hold that petitioner’s position in this proceeding is frivolous and has been interposed primarily to protest the tax laws of this country and/or to delay collection activity by respondent. We note that petitioner was made aware on several occasions that his arguments were considered frivolous and without merit. Accordingly, we hold that petitioner is liable for a $2,000 penalty under section 6673(a)(1). To reflect the foregoing, An appropriate order and decision will be entered granting respondent’s motion for summary judgment.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011