- 8 - Court to impose a penalty on a taxpayer who has instituted or maintained a proceeding primarily for delay, or whose position is frivolous or groundless. We gave petitioner an opportunity to raise legitimate arguments and to abandon his specious legal position, but he chose not to pursue this opportunity. Since petitioner failed to raise any meaningful arguments, we conclude that he instituted and maintained this proceeding primarily for delay. We shall impose a penalty of $1,500. D. Conclusion Petitioner was given an opportunity to raise relevant issues at trial and on brief. He did not raise any relevant issues at trial and did not file a posttrial brief with the Court. Because petitioner has not shown that he would have raised any relevant issues at a hearing, we conclude that it is unnecessary to decide whether he received a hearing. Accordingly, we hold that respondent’s determination to proceed with collection was not an abuse of discretion. An order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011