David J. Edwards - Page 21

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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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