-11- otherwise make any legitimate attempt to prove respondent’s determinations wrong. Petitioner was warned by respondent before trial, and he was warned by the Court during trial, that his position (or lack thereof) was without merit and could subject him to a penalty of up to $25,000 under section 6673(a). Notwithstanding the fact that we previously sanctioned petitioner in Hill v. Commissioner, T.C. Memo. 2002-272, for $3,500, petitioner continues to pursue his frivolous and/or groundless arguments. Petitioner has disregarded these warnings and has consumed wastefully the time, resources, and effort of the Court. We conclude from the record that petitioner’s positions in this proceeding are frivolous and without merit. We also conclude from the record that petitioner has instituted and maintained this proceeding primarily for delay. Pursuant to section 6673(a), we require petitioner to pay to the United States a penalty of $15,000.1 1 We note that petitioner has two more cases before the Court (docket Nos. 8690-02 and 14771-02).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011