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frivolous or groundless positions in the proceedings or
instituted the proceedings primarily for delay.
In the petition, petitioner alleged that the deficiencies
determined by respondent are excise taxes. This argument is
frivolous and groundless.
At trial, petitioner mainly objected to the admission of any
evidence that tended to prove that he earned income during the
years in issue and sought to impugn the integrity of his former
employers by implying that they overstated the income they paid
him in order to obtain a fraudulently higher deduction (for
compensation paid) on their own tax returns. He feigned lack of
memory regarding his earnings during the years in issue even
though he admitted working for all the employers who were called
as witnesses and that he was paid for services he rendered to
those employers. Furthermore, in a home loan application
petitioner signed in 2001, petitioner listed his monthly income
as $9,625.
Petitioner established his pattern of delay early on when he
failed to cooperate with respondent. Petitioner failed to meet
with or to provide respondent with any information that would
have enabled respondent to properly determine petitioner’s tax
liability or resolve this case without trial. Furthermore, after
asking the Court for additional briefing time at the conclusion
of the trial, petitioner failed to file any posttrial briefs. We
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Last modified: May 25, 2011