Steven and Jean L. Liddane - Page 3




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          those returns the wage income or interest income received during            
          1993 or 1994.                                                               
               Petitioners had a prior case before this Court, docket No.             
          15738-96, involving their tax liability for 1992.  In Liddane v.            
          Commissioner, T.C. Memo. 1998-259, filed July 14, 1998, the Court           
          rejected petitioners' frivolous arguments that they were not                
          liable for Federal income tax and imposed a penalty of $2,500               
          under section 6673.                                                         
               These cases were submitted on February 1, 1999, and                    
          respondent moved for a penalty under section 6673 in the amount             
          of $10,000, citing petitioners' prior case and pointing out that            
          petitioners are raising and asserting here the same frivolous               
          arguments for nonpayment of taxes that were rejected in the prior           
          case.  Nonetheless, petitioners filed a brief in which they                 
          reasserted the same partially incomprehensible but thoroughly               
          frivolous arguments that they are not liable for Federal income             
          taxes on the income that petitioners received in 1993, 1994, and            
          1995.  They argue that income taxes are voluntary, that wages are           
          not taxable, and that the statutory notices are invalid for                 
          failure to cite legal authority imposing income taxes on                    
          petitioners.                                                                
               Petitioners' various arguments were addressed in T.C. Memo.            
          1998-259, and there is no reason to repeat that analysis here.              
          Petitioners have stipulated the amounts of their interest income            





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