- 9 - section 6673(a)(2).3 Because no justiciable issues were presented, the bringing of the case in and of itself is nothing more than a delaying tactic requiring the use of Government and Court resources that could otherwise be applied to hear legitimate taxpayer concerns. While no penalty is being imposed in this line of cases, Mr. Jewett is reminded of the consequences if he repeats or persists in similar arguments in the future. See sec. 6673(a)(2); Takaba v. Commissioner, 119 T.C. 285, 296- 305 (2002); Edwards v. Commissioner, T.C. Memo. 2003-149. In reaching our holdings herein, we have considered all arguments made, and to the extent not mentioned above, we conclude them to be moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for respondent. 3 Sec. 6673(a)(2) provides, in part, as follows: (2) Counsel’s liability for excessive costs.--Whenever it appears to the Tax Court that any attorney or other person admitted to practice before the Tax Court has multiplied the proceedings in any case unreasonably and vexatiously, the Tax Court may require-- (A) that such attorney or other person pay personally the excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct * * *Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011