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notice of deficiency and as alleged in respondent’s amended
answer.
E. Section 6673(a)(1) Sanctions
Respondent filed a written motion requesting that we impose
sanctions on petitioner pursuant to section 6673(a)(1). Section
6673(a)(1) authorizes the Tax Court to require a taxpayer to pay
to the United States a penalty not in excess of $25,000 whenever
it appears that proceedings have been instituted or maintained by
the taxpayer primarily for delay or that the taxpayer’s position
in such proceedings is frivolous or groundless.
Petitioner has been uncooperative in preparing this case for
trial. He has been disingenuous and evasive in his testimony,
feigning memory lapses when questioned about his employment
history. The positions he has advanced are groundless or
frivolous. It appears that he has instituted and maintained
these proceedings primarily for purposes of delay. Although
petitioner was warned repeatedly both before and during trial
that his antics could result in the imposition of sanctions under
section 6673, he has been undeterred. Petitioner has
unreasonably protracted these proceedings and wasted the
resources of respondent and this Court. Pursuant to section
6673, we require petitioner to pay to the United States a penalty
of $5,000.
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Last modified: May 25, 2011