- 13 -
exceed $25,000 whenever it appears to the Court the taxpayer’s
position is frivolous or groundless. Sec. 6673(a)(1)(B).
Respondent has asked us to impose a penalty against petitioner
under section 6673(a). We have imposed a penalty under section
6673 on taxpayers who have raised arguments similar to those
petitioner has raised. See, e.g., Roberts v. Commissioner, 118
T.C. 365 (2002), affd. per curiam 329 F.3d 1224 (11th Cir. 2003);
Pierson v. Commissioner, 115 T.C. 576 (2000). We will not impose
a penalty here, but we caution petitioner that in the future
should he bring similar arguments before this Court, the Court is
likely to impose such a penalty.
To reflect the foregoing,
Decision will be entered
for respondent.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: November 10, 2007