- 15 - instituting or maintaining actions under those sections primarily for delay or by taking frivolous or groundless positions in such actions. In the Court’s Order dated March 17, 2003, and at trial, the Court reminded petitioner about section 6673(a)(1) and indicated that, in the event that petitioner continued to make statements, advance contentions and arguments, and/or raise questions that the Court finds to be frivolous and/or groundless, the Court would be inclined to impose a penalty under that section. Nonetheless, petitioner continued to adhere to those statements, contentions, and arguments. In the instant case, starting around April 26, 2000, when petitioner submitted to respondent amended returns for his taxable years 1995 and 1996, through the trial in this case, petitioner has advanced, we believe primarily for delay, frivo- lous and/or groundless contentions, arguments, and requests with respect to petitioner’s unpaid liabilities for 1995 and 1996, thereby causing the Court to waste its limited resources in addressing such matters. As a result of petitioner’s position and actions in the instant case with respect to petitioner’s unpaid liabilities for 1995 and 1996, we shall impose a penalty on petitioner pursuant to section 6673(a)(1) in the amount of $1,500. We have considered all of petitioner’s contentions, argu- ments, and requests that are not discussed herein, and we findPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011