- 5 - the taxpayer primarily for delay or that the taxpayer's position in such proceeding is frivolous or groundless. A taxpayer’s position is frivolous or groundless if it is “‘contrary to established law and unsupported by a reasoned, colorable argument for change in the law.’” Williams v. Commissioner, 114 T.C. 136, 144 (2000) (quoting Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir. 1986)). We find that petitioner has advanced frivolous and groundless statements, contentions, and arguments. We further find that petitioner has instituted this proceeding primarily for delay. Under the circumstances presented, we shall impose on petitioner a penalty in the amount of $5,000. To reflect the foregoing, An appropriate order of dismissal and decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011