- 9 - could proceed with the collection of petitioner’s tax liabilities for 2000, 2001, and 2002, and we imposed a $5,000 penalty pursuant to section 6673(a)(1). We find that petitioner has asserted frivolous and groundless arguments in this proceeding which are similar to those advanced in his prior case before this Court. We also find that petitioner instituted this proceeding primarily for delay. Consequently, we hold that petitioner is liable for a $5,000 penalty pursuant to section 6673(a)(1). To reflect the foregoing, An appropriate order of dismissal and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011