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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
respondent.
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Last modified: May 25, 2011