- 20 - on arguments akin to those raised herein summarily and with imposition of the section 6673 penalty. See, e.g., Craig v. Commissioner, 119 T.C. at 264-265 (and cases cited thereat). With respect to the instant matter, we are convinced that petitioner instituted this proceeding primarily for delay. Throughout the administrative and pretrial process, petitioner advanced contentions and demands previously and consistently rejected by this and other courts. She submitted lengthy communications quoting, citing, using out of context, and otherwise misapplying portions of the Internal Revenue Code, regulations, court decisions, and other authorities. Moreover, petitioner was, before this case was filed, explicitly alerted to Pierson v. Commisssioner, supra, and use of sanctions in analogous situations. Hence, petitioner received fair warning but has persisted in frivolously disputing respondent’s determination. The Court concludes that a penalty of $2,000 should be awarded to the United States in this case. To reflect the foregoing, An appropriate order granting respondent’s motion and decision for respondent will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011