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trust issue is not a sanctionable area. Ms. Spaid also takes
issue with respondent’s itemization of time spent on each
particular frivolous issue. She concludes with a request that we
reconsider our declared intention to impose sanctions under
section 6673(a)(2).
We will not reconsider our position under section
6673(a)(2). The “Delpit”, “Scar”, and “Agency” arguments have
been rejected by this and other courts as frivolous. See Edwards
v. Commissioner, T.C. Memo. 2002-169. Ms. Spaid, contrary to her
assertions, did not advance any good-faith arguments for changes
in existing law. Instead, she cobbled together a few out-of-
context quotes from cases that do not stand for the propositions
for which she cites them, and she never acknowledged the
existence of the substantial bodies of law contrary to her
frivolous positions.
Ms. Spaid’s assertion that the abusive trust issue is not a
“sanctionable area” again illustrates her penchant for practicing
law without reading cases. In our opinion in Edwards, we stated
clearly that the abusive trust issue was a frivolous issue and
observed that respondent had provided petitioner with copious
citations of our prior cases holding trusts like his to be
invalid abusive trusts. Notwithstanding the parties settled the
abusive trust issue in respondent’s favor, that happened only
shortly before posttrial briefs were originally due; Ms. Spaid is
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