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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 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).
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Last modified: May 25, 2011