Andrew Chook - Page 11

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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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