Damages for frivolous or groundless appeal or appeal to delay.

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(2) As used in this section:

(a) A taxpayer’s position is "frivolous" if there was no objectively reasonable basis for asserting the position.

(b) "Position" means any claim, defense or argument asserted by a taxpayer without regard to any other claim, defense or argument asserted by the taxpayer. [1987 c.843 §4; 1995 c.650 §6a; 2009 c.640 §5]


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