Robert and Ines M. Gillespie, et al. - Page 17




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          the following stipulation:  Ms. Osborn is a forensic accountant;            
          she is not recognized as an enrolled agent before the IRS, she              
          reviewed petitioners’ records and advised counsel for petitioners           
          that the assessments were time barred.                                      
               Both Mr. Jones and Ms. Lacorte were accorded the opportunity           
          to be heard with respect to our orders to show cause why excess             
          costs should not be imposed on them pursuant to section                     
          6673(a)(2), but each preferred to respond to our orders in                  
          writing.                                                                    
                                     Discussion                                       
          I.  Introduction                                                            
               Section 6673(a) provides for the imposition of sanctions and           
          the award of costs in Tax Court proceedings.  In pertinent part,            
          the provision provides:                                                     
               SEC. 6673.  SANCTIONS AND COSTS AWARDED BY COURTS.                     
                    (a)  Tax Court Proceedings.--                                     
                           (1) Procedures instituted primarily for                    
                    delay, etc.–-Whenever it appears to the Tax Court                 
                    that--                                                            
                              (A) proceedings before it have been                     
                           instituted or maintained by the taxpayer                   
                           primarily for delay,                                       
                              (B) the taxpayer’s position in such                     
                           proceeding is frivolous or groundless, or                  
                              (C) the taxpayer unreasonably                           
                           failed to pursue available                                 
                           administrative remedies,                                   








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