- 6 - repeated in petitioner’s trial memorandum signed by Mr. Jewett and filed with the Court. Before the calendar call for the instant case, Mr. Jewett had been advised by the Court in a conference call with respondent’s counsel in a substantially identical case that the arguments presented were frivolous and that the taxpayers could have penalties imposed against them under section 6673. At the call of the calendar, Mr. Jewett acknowledged the Court’s warning to him. Mr. Jewett also confirmed that he had informed petitioner of the possibility that penalties could be imposed against him. Petitioner authorized Mr. Jewett to proceed with the same arguments in spite of the warning. Discussion During the trial session held in Cleveland, Ohio, beginning June 2, 2003, four cases, including the instant case, were submitted fully stipulated.1 Mr. Jewett represented the taxpayers in each of the four cases. Dunham v. Commissioner, T.C. Memo. 2003-260, and Brodman v. Commissioner, T.C. Memo. 2003-230, were the first two of the four cases to be decided. We concluded in both cases that the taxpayers raised no bona fide issues, proposed no alternatives to 1 James Benson and Melanie A. Dunham, docket No. 7029-02L; Gregory R. Brown, docket No. 8368-02L; Harold V. and Imogene N. Pahl, docket No. 11572-02L; Charles and Teresa Brodman, docket No. 16598-02L.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011