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an unequivocal warning to taxpayers concerning the imposition of
a penalty 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.
In the petition and several other documents petitioner has
submitted to the Court, petitioner raised frivolous tax-protester
arguments and contentions that we have previously rejected and
which we conclude were interposed primarily for delay. This has
caused the Court to waste its limited resources. Accordingly, we
shall impose a penalty of $5,000 pursuant to section 6673.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011