- 52 - 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 taxPage: Previous 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 Next
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