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system. See Hamzik v. Commissioner, T.C. Memo. 2004-223;
Gilligan v. Commissioner, T.C. Memo. 2004-194.
In the present case, respondent requested that the Court
impose a penalty pursuant to section 6673(a)(1). By taking
frivolous and groundless positions regarding the Federal income
tax system, some of which have been summarized above, petitioner
abused the protections afforded under section 6330. Petitioner
was warned by the Appeals Office that sanctions could result if
she continued to make frivolous and groundless arguments.
Petitioner continued to do so, and in petitioning this Court for
review, she has wasted the limited resources of this Court.
Accordingly, we shall impose a penalty pursuant to section
6673(a)(1) in the amount of $2,000.
On the record before us, we shall grant respondent’s motion.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An order granting
respondent’s motion and
decision for respondent
will be entered.
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Last modified: May 25, 2011