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anything to do with the Uniform Commercial Code?" He also stated
that he did not "see a corpus delicti" in this case.
In sum, petitioner has advanced trite constitutional
arguments in his submissions to this Court and at trial.
Petitioner has received $412,221 during the tax years in issue
yet has steadfastly refused to honor his obligation to pay taxes.
Indeed, his actions have wasted the time and resources of the
Internal Revenue Service and this Court. Accordingly, we hold
that petitioner's position in these proceedings is frivolous and
groundless, and the Court shall impose a penalty of $10,000.
Respondent's motion for sanctions
will be granted, and decision will be
entered for respondent.
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Last modified: May 25, 2011