- 7 - 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 proceedings is frivolous or groundless. The various arguments that petitioner has made in this case have long been discredited and patently were asserted for purposes of delay. Petitioner has ignored warnings from respondent and this Court that his antics could result in the imposition of sanctions under section 6673. Petitioner has unreasonably protracted these proceedings and wasted the resources of respondent and this Court. Pursuant to section 6673, we require petitioner to pay to the United States a penalty of $1,000. To reflect the foregoing, An appropriate order and decision will be entered. 2(...continued) petitioner to have conceded this issue. In any event, the stipulated facts satisfy respondent’s burden of production with respect to this penalty. See sec. 7491(c).Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011