- 27 - or thereafter, there is no abuse of discretion in the conclusion reached in the 2004 supplemental determination. See RRA 1998 sec. 3401(d), 112 Stat. 750; Parker v. Commissioner, 117 T.C. 63 (2001); Parker v. Commissioner, T.C. Memo. 2005-294. Section 6673 Penalty In both his withdrawn and denied motions for summary judgment, respondent sought imposition on petitioner of a penalty under section 6673(a). Section 6673(a)(1) authorizes this Court to impose a penalty of up to $25,000 upon the taxpayer whenever it appears that proceedings have been instituted or maintained by him primarily for delay or his position is frivolous or groundless. Respondent having raised the issue, the Court considers it. A substantial portion of the contentions raised by petitioner are classic, shopworn tax protester arguments. At trial, petitioner maintained that he had no income tax liability for 1990 through 1993 because he received income in exchange for his labor. The Forms 1040X petitioner submitted for 1990, 1991, and 1993 to dispute his previously reported tax liabilities all contained such arguments as "no Code section makes me 'liable' for income taxes", and "'income' * * * can only be a derivative of corporate activity." Advancing such arguments in this Court,Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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