Diana Cote - Page 8

          Commissioner, supra.  Petitioner has neither offered an                     
          explanation for her failure to file nor produced evidence to                
          establish any reasonable cause for her failure to file the                  
          return.  We sustain respondent’s determination of an addition to            
          tax under section 6651(a)(1) in the amount to be calculated by              
          the parties in their Rule 155 computation.                                  
          4.   Section 6673(a)(1)                                                     
               Section 6673(a)(1) provides that this Court may require a              
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000 whenever it appears either that the taxpayer instituted             
          or maintained the proceedings primarily for delay or that the               
          taxpayer’s position in the proceeding is frivolous or groundless.           
               On the basis of the record before us, we are convinced that            
          petitioner has instituted and maintained these proceedings                  
          primarily for delay.  Petitioner failed to submit to the Court a            
          pretrial memorandum as directed by the Court’s standing pretrial            
          order and failed to attend the calendar call, either personally             
          or through counsel.  Petitioner also failed to appear at trial.             
          While petitioner was at that time ostensibly represented by                 
          counsel who did appear on petitioner’s behalf, petitioner’s                 
          counsel neither presented a case nor offered any evidence on                
          petitioner’s behalf.  Moreover, following trial, neither                    
          petitioner nor her counsel submitted a brief as we ordered.                 
          Petitioner has never responded to respondent’s motion to impose a           

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