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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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Last modified: May 25, 2011