- 17 - v. Commissioner, 99 T.C. 202, 222 (1992). Petitioner reported a tax liability in 1998 of $9,258 and owed tax in each of years in issue, yet failed to make any estimated payments. We therefore hold that petitioner is liable for the addition to tax under section 6654 for taxable years 1999 through 2002. 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. The record indicates that petitioner was warned that this Court could impose a penalty if he persisted in raising frivolous tax protester arguments. Despite being warned, petitioner raised frivolous arguments throughout the Appeals process, in his petition to this Court, and in his briefs. Accordingly, we shall impose a $10,000 penalty on petitioner pursuant to section 6673. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011