Richard John Kadunc - Page 8

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            immaterial in this case.  Moreover, petitioner had been placed on                         
            notice, by the holding in his previous case, that such evidence                           
            and the arguments in connection therewith possessed no merit.                             
                  The voluminous documents petitioner presented to this Court                         
            had no relevance to his case.  When that is coupled with his                              
            nonsensical arguments, the Court is provoked to apply the penalty                         
            under section 6673(a)(1).  The fact that petitioner believed, or                          
            may have believed, that he was entitled to a larger home interest                         
            deduction for 1991 than the amount allowed by respondent is of no                         
            consequence in this matter.  In Sloan v. Commissioner, 102 T.C.                           
            137, 148 (1994), affd. 53 F.3d 799 (7th Cir. 1995), this Court                            
            observed that "The mere fact that not every one of petitioner's                           
            arguments is frivolous or groundless does not eliminate the                               
            applicability of section 6673."  See also Granado v.                                      
            Commissioner, 792 F.2d 91, 94 (7th Cir. 1986), affg. T.C. Memo.                           
            1985-237.  Petitioner's possible belief with regard to his home                           
            interest deduction does not shield him from the imposition of the                         
            penalty under section 6673(a)(1).  By far, the majority of                                
            petitioner's pleadings and arguments are frivolous and                                    
            demonstrate that petitioner regarded this case as a vehicle to                            
            protest the tax laws of this country and espouse his own                                  
            misguided views.  This Court does not look with favor upon such                           

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