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$25,000 whenever it appears to the Court that the taxpayer’s
position in the proceeding is frivolous or groundless. Sec.
6673(a)(1)(B).
In Israel v. Commissioner, T.C. Memo. 2003-198, we imposed a
penalty on petitioner pursuant to section 6673(a)(1) in the
amount of $1,500 because petitioner had:
advanced, we believe primarily for delay, frivolous
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. * * *
At trial in the instant cases, the Court warned petitioner on
three separate occasions that the Court has penalized taxpayers
under section 6673 for bringing frivolous and meritless cases
before the Court, giving petitioner the citations of cases in
which the Court imposed the penalty.
Despite the warnings of the Court, petitioner has continued
to assert groundless arguments. Under the circumstances, we
shall, on our own motion, impose a penalty on petitioner pursuant
to section 6673(a)(1) in the amount of $5,000.
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Last modified: May 25, 2011