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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(a). As previously
mentioned, the Court has imposed penalties on petitioner under
section 6673(a) in the prior deficiency proceedings.
As discussed above, petitioner prosecuted this case
primarily to delay collection of his unpaid tax liabilities.
Petitioner’s arguments were devoid of any merit and caused a
needless waste of judicial resources. Taxpayers who promptly pay
their taxes should not have to bear the cost of Government and
tax collection associated with citizens who are unwilling to obey
the law or shoulder their assigned share of the Government’s
cost. This is the third case for this petitioner to result in a
section 6673 penalty, the most recent of which, at docket No.
6546-00, imposed a penalty of $7,500. It is appropriate that the
amount of such penalty increase where petitioner continues to
abuse the judicial process. Accordingly, the Court concludes a
section 6673 penalty of $10,000 shall be awarded to the United
States in this case.
To reflect the foregoing,
An order and decision will
be entered granting respondent's
motion to permit levy and motion
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