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Respondent, on brief, asserts that the Court should impose a
penalty pursuant to section 6673(a)(1). Petitioner is no
stranger to the Court or to the section 6673 penalty. Petitioner
raised frivolous arguments in his first trial which involved the
taxable years in issue here of 1994, 1995, and 1996. Petitioner
made similar arguments in a 2005 trial, regarding a deficiency
and additions to tax for his 2001 taxable year, and was ordered
to pay $5,000 to respondent for again asserting frivolous
arguments. Leggett v. Commissioner, supra. Despite repeated
warnings by the Court in petitioner’s two previous trials and the
imposition of a section 6673 penalty, petitioner repeated the
same frivolous arguments in this current case although he did not
dwell on them at trial. The Court is convinced that petitioner’s
positions are frivolous and made at least in part for delay.
Therefore, the Court concludes that a penalty of $2,500 should be
imposed on petitioner.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing,
An appropriate decision
will be entered.
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Last modified: May 25, 2011