Brief for Commissioner of Internal Revenue-Appellee: Table of Contents


  1. The Tax Court correctly granted summary judgment for the Commissioner upholding the Commissioner's proposed collection action where taxpayer's arguments were without merit and where there were no facts in dispute
  2. Standard of review
    1. Introduction
    2. Taxpayer raised only groundless arguments
  3. The Tax Court correctly imposed a $5,000 sanction under I.R.C. §6673 because taxpayer's position was patently groundless and he was aware of that fact
  4. Standard of review