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of his taxes. Therefore, we decline to impose a penalty under
section 6673(a), but admonish petitioner that we shall not be
inclined to exercise our discretion so favorably in the future if
he persists in pursuing frivolous arguments before this Court.
See Sides v. Commissioner, T.C. Memo. 2004-141; Kaeckell v.
Commissioner, T.C. Memo. 2002-114.
In reaching our holding herein, we have considered all
arguments made, and, to the extent not mentioned above, we
conclude that they are irrelevant or without merit.
Decision will be
entered for respondent.
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Last modified: May 25, 2011