- 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