-19- Q [Mr. KUTTEN] Your prior Tax Court trial, was it in this very same room, Mr. Harrell, where you’re sitting today? A [PETITIONER] That’s correct. Yes. Q And did you make basically the same arguments to the Court then? A Basically the same argument as the issue today? Q Yes. A Part of the issue is the issue I’ve raised today. Yes. Q And the Court stated that your arguments were frivolous. Is that not correct? A I believe that’s correct, that that was the terminology used someplace in the decision. Whether it was by the Tax Court or the Appeals Court, I don’t recall. In view of the fact that petitioner disregarded the Court’s warning and persisted in presenting frivolous arguments that have been firmly rejected by this Court and others in the past, and that petitioner persisted in presenting such arguments after having been warned twice during the course of the instant case, we conclude that petitioner’s conduct justifies imposing a substantial penalty on petitioner; we award a penalty to the United States in the amount of $10,000 under the provisions of section 6673. To take account of the foregoing, including the matters described supra notes 1 and 2, Decision will be enteredPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011