Isaiah Israel - Page 15

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          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 find              






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