Cynthia Ann Schlosser - Page 7
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citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417 (5th Cir. 1984).
On the basis of our review of the record, we conclude that
there is no genuine issue as to a material fact. In the absence
of a valid issue for review, we conclude that respondent is
entitled to judgment as a matter of law and sustain respondent’s
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not to exceed
$25,000 if the proceedings have been instituted or maintained by
the taxpayer primarily for delay or the taxpayer’s position is
frivolous and groundless. Petitioner’s position is frivolous and
groundless and has caused this Court to waste limited resources.
Accordingly, we hold that petitioner is liable for a $1,000
penalty pursuant to section 6673(a).
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: November 10, 2007