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on the basis of the record of this case, we find that there
is no genuine issue as to any material fact, and that a
decision may be rendered for respondent as a matter of law.
It is necessary to give petitioner a word of warning.
The Court considers petitioner’s position in this case to
be frivolous or groundless. It also appears that he has
instituted or maintained these proceedings primarily for
delay. Section 6673(a) authorizes the Court to require
a taxpayer to pay to the United States a penalty not in
excess of $25,000 whenever it appears to the Court that:
(a) Proceedings before it have been instituted or
maintained by the taxpayer primarily for delay; (b) the
taxpayer’s position in such proceeding is frivolous or
groundless; or (c) the taxpayer unreasonably failed to
pursue available administrative remedies. Sec. 6673(a)(1).
Petitioner is hereby warned that the Court will not
hesitate to impose a penalty under section 6673(a) against
him in any appropriate case in the future.
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Last modified: May 25, 2011