- 3 - 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.Page: Previous 1 2 3
Last modified: May 25, 2011