Thomas V.F. Struhar - Page 9

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          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.                          










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