David J. Edwards - Page 52




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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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