Geoffrey K. J. Yuen - Page 9

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          penalty upheld because taxpayer should have known claim was                 
          frivolous).                                                                 
               In a previous appearance before this Court, petitioner made            
          similar frivolous tax-protester arguments.  In that case,                   
          involving prior tax years, we imposed a penalty pursuant to                 
          section 6673 on for advancing frivolous arguments in this Court.            
          Yuen v. Commissioner, docket No. 15296-03L.                                 
               In the petition and at trial, petitioner raised frivolous              
          arguments and contentions that we have previously rejected and              
          which we conclude were interposed primarily for delay.  This has            
          caused the Court to waste limited resources.  Accordingly, on our           
          own motion, we shall impose a penalty of $5,000 pursuant to                 
          section 6673.                                                               
               To reflect the foregoing,                                              
                                                  An appropriate order and            
                                             decision will be entered.                



















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