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petitioner’s 1996 taxable year as set forth in the notice
of determination.
We note that section 6673(a)(1) authorizes the Court to
require a taxpayer to pay to the United States a penalty of
up to $25,000 whenever it appears that the proceeding has
been instituted or maintained by the taxpayer primarily for
delay or that the taxpayer’s position in such proceedings is
frivolous or groundless. In this case, we conclude that the
position advanced by petitioner is frivolous and groundless.
Nevertheless, respondent has not asked for penalties under
section 6673 to be imposed, and we choose not to do so at
this time. We caution petitioner that such penalties under
section 6673 may be imposed if he continues to advance the
same frivolous and groundless arguments in the future.
Upon consideration of the above,
An appropriate Order and
Decision authorizing respondent
to proceed with collection will
be entered.
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Last modified: May 25, 2011