Jerre Marvine Wood - Page 7

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          fact exists requiring trial.  Respondent is entitled to summary             
               Section 6673(a)(1) provides that this Court may require the            
          taxpayer to pay a penalty not in excess of $25,000 whenever it              
          appears to this Court:  (a) The proceedings were instituted or              
          maintained by the taxpayer primarily for delay; (b) the                     
          taxpayer’s position is frivolous or groundless; or (c) the                  
          taxpayer unreasonably failed to pursue available administrative             
          remedies.  Respondent has moved that the Court impose a penalty             
          in the instant case.  The record indicates that petitioner was              
          warned that this Court could impose a penalty if she persisted in           
          raising frivolous tax protester arguments.  Despite being warned,           
          petitioner raised frivolous arguments throughout the section 6330           
          administrative process, in her petition to this Court, and in her           
          response, as supplemented, to respondent’s motion.  Accordingly,            
          we shall impose a $1,000 penalty on petitioner pursuant to                  
          section 6673.                                                               
               To reflect the foregoing,                                              

                                            An appropriate order and                  
                                       decision will be entered.                      

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Last modified: May 25, 2011