- 17 - and 1997.10 In respondent’s motion, respondent requests that the Court require petitioner to pay a penalty to the United States pursuant to section 6673(a)(1). Section 6673(a)(1) authorizes the Court to require a taxpayer to pay a penalty to the United States in an amount not to exceed $25,000 whenever it appears that a taxpayer instituted or maintained a proceeding in the Court primarily for delay or that a taxpayer’s position in such a proceeding is frivolous or groundless. In the Court’s February 22, 2006 Order, the Court, inter alia, reminded petitioner about section 6673(a)(1) and admonished him that, in the event he were to advance frivolous and/or groundless statements, contentions, and arguments in his response to respondent’s motion, the Court would be inclined to impose a 10The attachment to the notice stated in pertinent part: I recommend a determination letter be issued to the taxpayer sustaining the filing of Notice of Federal Tax Lien. For the years 1980, 1981, * * * tax liability has been paid. * * * * * * * * * * When the Notice of Federal Tax Lien was filed [with respect to petitioner’s taxable years 1980, 1981, 1982, 1983, 1984, 1992, and 1997] it was appropriate. The liability was valid and outstanding. After the notices of Federal tax lien with respect to peti- tioner’s taxable years 1980 through 1984, 1992, and 1997 were filed and before the notice of determination was issued, the unpaid liability for each of his taxable years 1980 and 1981 was paid.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011