Isaiah Israel - Page 6

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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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