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Nothing in petitioner’s arguments suggests any justiciable
dispute with respect to the income determinations or additions to
tax made by respondent. Funk v. Commissioner, 123 T.C. 213
(2004).
Accordingly, and given that this is the second time that
petitioner comes before the Court with the same frivolous
arguments, we award a penalty to the United States in the amount
of $5,000, pursuant to section 6673.
For the reasons stated herein, respondent’s motion for
summary judgment will be granted under Rule 121. The order and
decision granting respondent’s motion will require petitioner to
pay a penalty to the United States in the amount of $5,000
pursuant to section 6673.
Reviewed and adopted as the report of the Small Tax Case
Division. To reflect the foregoing,
An appropriate order and decision
will be entered.
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Last modified: May 25, 2011