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115 T.C. 576 (2000), in which this Court issued an unequivocal
warning to taxpayers concerning the imposition of penalties
pursuant to section 6673(a) on those taxpayers who abuse the
protections afforded by sections 6320 and 6330 by instituting or
maintaining actions under those sections primarily for delay or
by taking frivolous or groundless positions in such actions. At
trial, the Court advised petitioners that the arguments they were
advancing had been universally rejected by the courts that have
considered them. Petitioners’ positions, based on stale and
meritless contentions, are manifestly frivolous and groundless.
This has caused the Court to waste limited resources.
Accordingly, we shall impose a penalty of $2,500 pursuant to
section 6673.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011