- 9 - 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.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011