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Internal Revenue Service could not be sued eo nomine, the
District Court in Diversified Metal merely drew a parallel in
that respect between the Internal Revenue Service and the United
States Civil Service Commission. Nothing in the District Court’s
opinion supports petitioner’s argument that the Internal Revenue
Service is not an agency of the United States or that it lacks
authority to administer and enforce the internal revenue laws.
In sum, the statutory authority of the Commissioner and the
Internal Revenue Service is indisputable. The Courts have
repeatedly held that the Internal Revenue Service is an
authorized agency of the United States and rejected as frivolous
arguments to the contrary. Petitioner cited no genuine authority
for his position and failed to cite the substantial body of
contrary authority directly on point. Finally, petitioner failed
to make a nonfrivolous argument for the extension, modification,
or reversal of existing law or the establishment of new law.
Petitioner’s argument that the Internal Revenue Service is not an
agency of the United States and is not authorized to administer
and enforce the internal revenue laws is frivolous and groundless
within the meaning of section 6673(a)(1)(B).
The Abusive Trusts
Petitioner conceded after trial and before the parties’
posttrial briefs were due that the trusts should be disregarded
for Federal income tax purposes. In his Federal income tax
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