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The Court further warned petitioner that, if he persisted,
damages would be imposed under section 6673. Section 6673(a)
provides that, if the Court determines that proceedings are
maintained by a taxpayer primarily for delay or the position of a
taxpayer is groundless or frivolous, the Court may award a
penalty to the United States in an amount not in excess of
$25,000.
At the hearing, petitioner maintained the course that he had
charted in his petition. Accordingly, respondent’s motion to
dismiss for failure to state a claim will be granted.
Furthermore, petitioner’s arguments advanced here are frivolous,
and we award a penalty to the United States of $5,000 under
section 6673.
An appropriate order of
dismissal and decision will be
entered.
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Last modified: May 25, 2011