- 12 - reasoning and copious citation of precedent; to do so might suggest that these arguments have some colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984); see Holliday v. Commissioner, T.C. Memo. 2005-240; Duffield v. Commissioner, T.C. Memo. 2002-53; Kuglin v. Commissioner, T.C. Memo. 2002-51. Petitioner has not presented any evidence or arguments to convince us that respondent abused his discretion. As a result, we hold respondent’s determination was not an abuse of discretion, and respondent may proceed with the proposed collection action. Section 6673(a)(1) authorizes the Court to require a taxpayer to pay the United States a penalty in an amount not to exceed $25,000 whenever it appears to the Court the taxpayer’s position is frivolous or groundless. Sec. 6673(a)(1)(B). Respondent has asked the Court to impose a penalty against petitioner under section 6673(a). There is no evidence that petitioner has previously been a litigant in this Court. However, the Court warned petitioner that if he continued to raise only frivolous arguments, a penalty could be imposed. Despite the warning, petitioner continued to assert only frivolous arguments. As a result, we hold that a penalty of $1,500 against petitioner is awarded to the United States pursuant to section 6673(a)(1).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011