- 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