Lawrence W. Wirenius - Page 7




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          a status they do not deserve.  Crain v. Commissioner, 737 F.2d              
          1417 (5th Cir. 1984)  Petitioner’s arguments are timeworn tax               
          protester arguments which have been rejected by the courts often            
          enough.                                                                     
               Petitioner states that he is not a tax protester and that he           
          has researched each of these arguments.  Our answer to petitioner           
          is that his research has never gone far enough.  He has never               
          found the many cases which have held his arguments to be invalid.           
          The short answer to petitioner’s arguments is that he is not                
          exempt from Federal income tax, and we so hold.                             
               Section 6673 authorizes the Court to award a penalty to the            
          United States not in excess of $25,000 whenever it appears to the           
          Court that proceedings have been instituted or maintained by the            
          taxpayer primarily for delay, the taxpayer’s position in such               
          proceedings is frivolous or groundless, or the taxpayer                     
          unreasonably failed to pursue available administrative remedies.            
          The arguments that petitioner presented to exempt himself from              
          tax liability are frivolous and groundless.                                 
               However respondent has not moved for an award under section            
          6673, and, in view of the petitioner’s success with regard to               
          several of the issues, we shall not impose this penalty at this             
          time.  However, petitioner should be advised that if he raises              
          these tax protester arguments in the future, the Court may                  







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