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Id. As a result of petitioner’s position and actions with
respect to the unpaid liabilities for 1995 and 1996, the Court
also imposed a penalty on petitioner pursuant to section
6673(a)(1) in the amount of $1,500. Id. Petitioner appealed
this decision to the U.S. Court of Appeals for the Seventh
Circuit, where it is currently pending.
In preparation for the Court’s trial session in Chicago,
Illinois, beginning September 22, 2003, the parties submitted for
each docket a supplemental stipulation of facts, in which
petitioner admitted to receiving all the disputed income. Each
supplemental stipulation, however, contained the following
statement: “It is petitioner’s position that this amount is not
subject to income tax because the statutory notice of deficiency
was not properly issued under federal law by the Secretary of
Treasury.” Further, petitioner filed with the Court trial
memoranda which contained similar frivolous and groundless
arguments.
At trial, the Court warned petitioner on three separate
occasions that the arguments he was making have been deemed
frivolous by the Court and that the Court has imposed penalties
under section 6673 against taxpayers who bring such frivolous
arguments before the Court. Additionally, the Court provided
petitioner with citations of three cases in which the Court
imposed a penalty pursuant to section 6673 because the taxpayers
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