- 7 -
that the Court will consider imposing such a penalty if
petitioner returns to the Court and advances similar arguments in
the future.”
Documents that petitioner attached to the commercial notice
indicate that, after this Court’s disposition of petitioner’s
previous case involving his 1999 liability, he filed a U.C.C.
Financing Statement describing the Judge in that case and
numerous employees of the Internal Revenue Service as debtors.
These documents indicate that the U.S. Department of Justice has
filed a complaint alleging that petitioner filed the U.C.C.
Financing Statement for purposes of retaliation and harassment.
At the trial session, respondent confirmed that petitioner had
filed the U.C.C. Financing Statement and that the U.S. Department
of Justice had begun the process of removing the lien arising
from that Financing Statement.
We find that petitioner has asserted frivolous and
groundless arguments in this proceeding, which are similar to
those advanced in his prior case before this Court. We also find
that petitioner instituted this proceeding primarily for delay.
We hold that petitioner is liable for a $20,000 penalty pursuant
to section 6673(a)(1).
Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011