- 6 - 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 taxpayersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011