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We have no doubt that petitioner, an educated individual,
maintained this proceeding primarily to delay the day the IRS
could collect taxes he owes for 1997. Petitioner has wasted the
time of respondent’s representatives, as well as the time of this
Court. We therefore impose a penalty of $3,000 on petitioner
under section 6673.
We have considered all the arguments and contentions made by
petitioner, and to the extent not discussed herein, we conclude
they are without merit and/or irrelevant.
To reflect the foregoing,
Decision will be entered for
respondent.
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Last modified: May 25, 2011