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Ruocco v. Commissioner, T.C. Memo. 2002-91. He was warned at the
calendar call and he had been warned by prior cases, including
his own, concerning his misguided arguments and that he could
expect to have a penalty under section 6673 awarded against him.
In his answers to interrogatories in this case, petitioner
asserted that documents and information needed to respond to
specific questions were in the hands of Chisum and John P. Wilde
(Wilde). (He also stated that Eileen Lipari was responsible for
the preparation of HOMC’s 1997 Federal income tax return. See
Lipari v. Commissioner, T.C. Memo. 2000-280.) In his prior case
and during the years in issue, petitioner claims to have relied
on Chisum. Chisum and Wilde are well known to the Court for the
multiple cases in which they have appeared in one form or
another, and they have been notably unsuccessful. See, e.g.,
Johnston v. Commissioner, supra; Quantum Invs., L.L.C. v.
Commissioner, T.C. Memo. 2000-247 (n.5); Renaissance Enters.
Trust v. Commissioner, T.C. Memo. 2000-226; Banana Moon Trust v.
Commissioner, T.C. Memo. 2000-73; Jeff Burger Prods., LLC v.
Commissioner, T.C. Memo. 2000-72; Bantam Domestic Trust v.
Commissioner, T.C. Memo. 2000-63. The Court’s records indicate
approximately 30 cases in which petitions were filed by Wilde as
either an alleged trustee or as the alleged tax matters partner
of an LLC and were ultimately dismissed by reason of Wilde’s
failure to show his authority to proceed or for other failures.
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