- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011