- 34 -
respondent was forced to obtain certified copies of these records
and offer them separately to the Court.
Petitioners filed a motion on June 5, 2000, requesting that
the notice be declared invalid, which motion the Court denied.
On October 2, 2000, petitioners filed another motion requesting
that the notice be declared invalid despite the fact that the
Court had already considered the issue, which motion the Court
again denied.
Finally, on brief, petitioners have failed to address the
substance of respondent’s objections.
5. Conclusion
Petitioners are deserving of a penalty under section
6673(a)(1). As we stated supra, sec. III.B.1.: The purpose of
section 6673 is to compel taxpayers to think and to conform their
conduct to settled principles before they file returns and
litigate. Petitioners are intelligent people. They know that,
when taken together, their returns and the trust returns
virtually eliminate their liability to pay tax by offsetting,
against income that they earned, deductions for personal expenses
that they could not have claimed on their own returns. Rita
Snyder is a professional preparer of tax returns and, we assume,
has sufficient experience to know that such scheme was
illegitimate. They failed to cooperate in respondent’s
examination and in preparation of this case for trial. They have
delayed these proceedings. Because of their stonewalling and
Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: May 25, 2011