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primarily for delay, and we so find. A taxpayer’s good faith
reliance on the advice of counsel is not a defense to the
imposition of a penalty under section 6673(a)(1)(B), nor need we
excuse a taxpayer’s failure to review pleadings and other
documents filed on his behalf. The purpose of section 6673 is to
compel taxpayers to think and to conform their conduct to settled
principles before they file returns and litigate. Takaba v.
Commissioner, 119 T.C. 285, 295 (2002); see also Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986). Indeed,
petitioners were warned by the settlement officer that, by
asserting unfounded allegations of procedural defects, they
risked exposure to penalties under section 6673(a)(1).
Not only do we determine that petitioners are deserving of a
penalty for conduct that violates section 6673(a)(1)(A) and (B),
but we believe that they are deserving of a penalty pursuant to
section 6673(a)(1)(C) for unreasonably failing to pursue
available administrative remedies. As summarized in our
background discussion under the heading Determinations,
petitioners neither proposed any collection alternatives nor
provided the settlement officer the financial information
necessary to consider collection alternatives. Assuming that
they had a case to make to the settlement officer, petitioners
did not act reasonably in presenting less than their full case to
her during the administrative process.
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Last modified: November 10, 2007