- 5 - clear statement of error and contained “nothing more than frivolous rhetoric and legalistic gibberish”). Respondent also requests that this Court impose a penalty pursuant to section 6673 because petitioner has instituted the proceeding primarily for delay. Respondent further contends that petitioner’s position is groundless or frivolous, and that petitioner filed this petition as a protest to paying income taxes. 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 that: (1) The taxpayer instituted or maintained the proceedings primarily for delay; (2) the taxpayer’s position in the proceeding is groundless or frivolous; or (3) the taxpayer unreasonably failed to pursue available administrative remedies. Petitioner has been notified repeatedly that this Court might impose a penalty pursuant to section 6673(a)(1) if he continued to assert frivolous arguments. Petitioner lodged with the Court what he captioned a “Commercial notice of administrative judgment by estoppel with respect to notice of international commercial claim within the admiralty administrative remedy agreement/contract file number LJF09092004 & UCC financing statement file number 05-7017217898” (commercial notice). Attached to the commercial notice was a letter from thePage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011