- 12 - the amount of $25,000. In pertinent part, section 6673(a)(1) authorizes the Court to require a taxpayer to pay to the United States a penalty in an amount not to exceed $25,000 whenever it appears to the Court that a proceeding before it was instituted or maintained primarily for delay, sec. 6673(a)(1)(A), or that the taxpayer’s position in such a proceeding is frivolous or groundless, sec. 6673(a)(1)(B). As evidenced by the petition and petitioner’s subsequent arguments, petitioner’s legal arguments are frivolous and he has no grounds justifying his claim that the Appeals officer erred in any manner. We can see no reason for the petition but to delay the collection of the 1997 income tax owing from petitioner. Petitioner has not only wasted his time, but he has wasted the time of respondent’s agents, officers, and counsel, not to mention the waste of the Court’s time in disposing of this case. We shall not penalize petitioner in the amount, $25,000, requested by respondent, but we do believe that petitioner deserves a significant section 6673 penalty. We shall therefore require petitioner pursuant to section 6673(a)(1) to pay to the United States a penalty in the amount of $7,500. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011