William R.Tinnerman - Page 17

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          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.                      








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