- 21 - 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 isPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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