Frank George - Page 11




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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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