- 13 -
arguments. After respondent filed his motion for summary
judgment and we issued an order requiring petitioners to respond,
petitioners did not comply with our order and did not file the
required response.
Petitioners’ conduct as summarized in this opinion
demonstrates that this proceeding was instituted and maintained
primarily for delay. Moreover, every argument made by
petitioners during the administrative appeal and in this Court
was frivolous and/or groundless. Consequently, a penalty under
section 6673(a)(1) is warranted. We shall require petitioners to
pay to the United States a penalty under section 6673(a)(1) of
$2,000.
An appropriate order and
decision will be entered.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011