- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011