New IRC section 6702(b) provides for a penalty of $5,000.00 if any portion of a request for a hearing under IRC sections 6320 and 6330 (CDP) is base on a “specified frivolous position”(Notice 2008-14), or reflects a desire to delay or impede the administration of federal tax laws.
The penalty will not be assessed if TP withdraws the CDP, but these guys are knuckleheads.
New $5,000.00 Penalty for Frivolous CDP
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- Pirate Judge of Which Things Work
- Posts: 321
- Joined: Thu Jan 22, 2004 6:13 pm
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Re: New $5,000.00 Penalty for Frivolous CDP
$5,000 is about 25 pool cleanings. The penalty seems about right.
Remember that CtC is about the rule of law.
John J. Bulten
John J. Bulten