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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.
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Last modified: May 25, 2011