- 9 -
liabilities was not an abuse of discretion.
C. Section 6673 Penalty
Section 6673(a) authorizes this Court to impose a penalty
not in excess of $25,000 on any taxpayer who institutes or
maintains proceedings in this Court primarily for delay, asserts
a position in such proceeding that is frivolous or groundless, or
unreasonably fails to pursue administrative remedies. It does
not appear from the record in this case that respondent warned
petitioner about section 6673 during the course of these
proceedings, and respondent does not request that we impose a
section 6673 penalty. However, we caution petitioner that his
arguments in this case were frivolous and that any reliance upon
those arguments in future tax disputes may result in the
imposition of the section 6673 penalty.
We have considered the remaining arguments of both parties
for results contrary to those expressed herein and, to the extent
not discussed above, find those arguments to be irrelevant, moot,
or without merit.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011