Denis J. Faris and Carolyn M. Faris - Page 9

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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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