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and of wage income received for Steven J. Liddane's services
during the years in issue, and they have raised no dispute as to
the computation of the tax on that income. Petitioners have
provided no reason why the additions to tax and accuracy-related
penalty should not be imposed. Because petitioners have pursued
the same frivolous claims in the face of the Court's prior
opinion, and for the reasons set forth in T.C. Memo. 1998-259, a
penalty under section 6673 in the amount of $10,000 in each
docketed case will be awarded.
Appropriate orders and
decisions will be entered.
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Last modified: May 25, 2011