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to cooperate with respondent during the administrative process
and appeals hearing. Petitioner’s timing of his bankruptcy
petition was clearly yet another attempt to delay or avoid
collection. Accordingly, we shall impose a penalty of $10,000
pursuant to section 6673.
VIII. Conclusion.
We hold that respondent may proceed with the proposed levy
to collect the tax liabilities for the years in issue.
To reflect the foregoing,
An appropriate decision
will be entered.
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