Kevin P. Burke - Page 14

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          delay in the collection process would be unconscionable.                    
          Accordingly, we shall grant respondent’s Motion to Permit Levy.             
          II.  Section 6673 Penalty                                                   
               Section 6673(a)(1) authorizes the Tax Court to require a               
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000 whenever it appears that proceedings have been instituted           
          or maintained by the taxpayer primarily for delay or that the               
          taxpayer's position in such proceeding is frivolous or                      
          groundless.  We warned taxpayers in Pierson v. Commissioner, 115            
          T.C. 576, 581 (2000), that abusing the procedural protections               
          afforded by sections 6320 and 6330 by pursuing frivolous lien or            
          levy actions for purposes of delaying the tax payment process               
          would result in sanctions under section 6673 when that section              
          was applicable.  We have since repeatedly warned taxpayers                  
          regarding section 6673, as we did petitioner here, and have                 
          repeatedly disposed of cases premised on arguments akin to those            
          raised here summarily and with imposition of the section 6673               
          penalty.  See Craig v. Commissioner, 119 T.C. 252, 265 (2002).              
               Petitioner was previously penalized for his frivolous                  
          arguments and delay perpetrated on the Court in connection with             
          docket No. 13410-00 concerning his tax liability for the tax                
          years 1993 through 1997.  Although in this action petitioner was            
          polite and eliminated several frivolous issues at trial, he                 
          nevertheless wasted judicial resources on other frivolous                   






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