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where a taxpayer’s procrastination has increased the costs of
litigation. See Griest v. Commissioner, T.C. Memo. 1995-165
($1,000 penalty imposed where a case was settled at the time of
trial after the taxpayer substantiated his basis to reduce sales
proceeds determined to be income).
Respondent filed a motion to impose a penalty under section
6673(a)(1)(C) for petitioner’s unreasonable failure to pursue
available administrative remedies. The record in this case
establishes repeated failures of petitioner to meet with
respondent and to provide information relevant to unreported
income at issue. Had petitioner provided such information, this
case might have been susceptible to settlement, which would have
decreased the costs of litigation. Additionally, petitioner was
deemed to have admitted that he unreasonably failed to pursue
available administrative remedies. Therefore, we shall grant
respondent’s motion and require petitioner to pay to the United
States a penalty of $1,000.
To reflect the foregoing,
An appropriate order
and decision will be entered.
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Last modified: May 25, 2011