- 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