Anthony P. Hart - Page 5
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he filed his brief that his arguments lack any basis in law and
have been previously rejected by this Court.
At the hearing, the Court asked respondent to send
petitioner a copy of our opinions in Liddane v. Commissioner,
T.C. Memo. 1998-259, affd. without published opinion 208 F.3d 206
(3d Cir. 2000); Cocozza v. Commissioner, T.C. Memo. 1997-305; and
Talmage v. Commissioner, T.C. Memo. 1996-114, affd. without
published opinion 99 F.3d 1131 (4th Cir. 1996), further to inform
petitioner that his arguments are frivolous and have been
repeatedly rejected by this Court, and that his continued
maintenance of these frivolous arguments could subject him to a
penalty of up to $25,000 under section 6673(a).
According to a motion filed by respondent after the hearing:
Respondent’s counsel contacted petitioner on or
about April 18, 2001, at which time petitioner stated
that he would sign a decision document based on the
amounts stated in the statutory notice of deficiency.
Respondent mailed a cover letter and a decision
document (attached) to petitioner on the same day.
Respondent left messages on petitioner’s answering
machine * * * on April 27, 2001 and May 2, 2001
inquiring whether petitioner had sent the signed
Commissioner’s determination of the fraud penalty against a tax
protester nonfiler. Grimes v. Commissioner, 82 T.C. 235 (1984),
awarded the Commissioner damages under a prior version of sec.
6673(a) against a taxpayer who continued to maintain the
frivolous positions taken in his petition. See also Grimes v.
Commissioner, 806 F.2d 1451 (9th Cir. 1986), affg. an unreported
order of this Court to impose damages against the same taxpayer
for a later year and also awarding additional damages to the
Government on account of the taxpayer’s frivolous appeal.
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