- 9 - respondent and the Court that his arguments were frivolous and without merit, and that if he continued to advance them he could be subject to a penalty of up to $25,000. Even after receiving these repeated warnings, petitioner continued to advance frivolous and meritless arguments. We conclude petitioner’s position was frivolous and groundless and that petitioner instituted and maintained these proceedings primarily for delay. Accordingly, pursuant to section 6673(a) we hold petitioner is liable for a $5,000 penalty. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9Last modified: November 10, 2007