Devery W. Hennard - Page 7

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               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.  Although we will not impose a penalty on petitioner            
          in this case, we will take this opportunity to admonish                     
          petitioner that the Court will consider imposing such a penalty             
          should he return to the Court and advance similar arguments in              
          the future.                                                                 
               To reflect the foregoing,                                              

                                                 An appropriate order and             
                                            decision will be entered for              

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Last modified: May 25, 2011