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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 because petitioner’s arguments are frivolous
and groundless. Petitioner received several warnings, including
one at the beginning of trial, that this Court could impose a
penalty if petitioner persisted in raising frivolous arguments.
Despite being warned, petitioner nonetheless raised frivolous
arguments and wasted the Court’s time. Accordingly, we shall
impose a penalty on petitioner of $5,000 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