- 12 -
In the instant case, petitioner advances, 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 petitioner
pursuant to section 6673(a)(1) in the amount of $11,000.
We have considered all of petitioner’s contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and/or irrelevant.8
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An appropriate order and deci-
sion will be entered for respondent.
7(...continued)
about sec. 6673(a)(1) and indicated that, in the event that
petitioner continued to make statements, advance arguments and
contentions, 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.
8We shall, however, address one of petitioner’s allegations
in the petition. Petitioner alleges in the petition that the
Court should order respondent to hold an Appeals Office hearing
with him. Respondent acknowledges that, pursuant to Internal
Revenue Manual 8.7.2.3.3(5)d, respondent’s Appeals Office should
have held a hearing with petitioner. However, relying on
Lunsford v. Commissioner, 117 T.C. 183, 189 (2001), respondent
contends that an Appeals Office hearing is not necessary or
productive in the instant case. We agree with respondent. We
have found petitioner’s statements, contentions, arguments, and
requests to be frivolous and/or groundless. We conclude that it
is not necessary or productive for respondent to hold an Appeals
Office hearing with petitioner. Id.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011