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Section 6673(a)(1) provides that the Court is authorized to
require a taxpayer to pay to the United States a penalty of up to
$25,000 whenever it appears that the taxpayer’s position in the
proceeding is frivolous and groundless. While a penalty will not
be imposed at this time, the Court cautions petitioner that a
penalty may be imposed if he continues to advance the same
frivolous and groundless arguments in the future.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011