26 U.S.C. § 6673 — Sanctions and costs awarded by courts

(a) Tax court^* proceedings. (1) If the Tax Court finds that a taxpayer^* started or maintained a case mainly to delay it, took a frivolous or groundless position, or unreasonably failed to use available administrative remedies, the Court may require the taxpayer to pay the United States up to $25,000. (2) If a Tax Court attorney or another admitted practitioner unreasonably and vexatiously multiplies a case, the Court may require that person to pay the excess costs, expenses, and reasonably incurred attorney fees personally. If the attorney represents the Commissioner^* of Internal Revenue, the Court may instead require the United States to pay those amounts as a district court would.

(b) Proceedings in other courts. (1) If a taxpayer’s position in a case brought or maintained under section 7433 is frivolous or groundless, the court may require payment to the United States of up to $10,000. (2) In a civil case other than in Tax Court involving the United States and the determination, collection, or refund of a tax, interest, or penalty under this title, monetary sanctions, penalties, or costs awarded to the United States may be assessed by the Secretary^* and collected after notice and demand in the same way as a tax. (3) In an appeal from a Tax Court case or such a civil case, an appeals court or the Supreme Court may award monetary sanctions, penalties, or court costs to the United States. The United States may register that order in a district court by filing a certified copy, and it is enforceable like other district-court judgments. The Secretary may assess those amounts and collect them after notice and demand in the same way as a tax.