Gregory R. Brown - Page 6

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          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.                                                              




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