G. Robert Lyman and Shari Lee Wright Lyman - Page 11

                                       - 11 -                                         
          tion of a penalty under 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            
               In the instant case, petitioners advance, we believe primar-           
          ily for delay, frivolous and/or groundless contentions, argu-               
          ments, and requests, thereby causing the Court to waste its                 
          limited resources.  We shall impose a penalty on petitioners                
          pursuant to section 6673(a)(1) in the amount of $3,000.                     
               We have considered all of petitioners’ contentions, argu-              
          ments, and requests that are not discussed herein, and we find              
          them to be without merit and/or irrelevant.                                 
               On the record before us, we shall grant respondent’s motion.           
               To reflect the foregoing,                                              
                                             An appropriate order granting            
                                        respondent’s motion and decision              
                                        will be entered for respondent.               

               7The record in this case reflects that the settlement offi-            
          cer gave petitioners, inter alia, a copy of the Court’s opinion             
          in Pierson v. Commissioner, 115 T.C. 576 (2000).                            

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  

Last modified: May 25, 2011