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brought frivolous and meritless cases before the Court:
Trowbridge v. Commissioner, T.C. Memo. 2003-165, Trowbridge v.
Commissioner, T.C. Memo. 2003-164, and Tornichio v. Commissioner,
T.C. Memo. 2002-291. Despite the Court’s warnings, petitioner
continued with the frivolous and groundless arguments at trial
and in his subsequent brief filed with the Court.
OPINION
I. Notices of Deficiency
Petitioner argues that the person who sent the notices of
deficiency did not have the delegated authority to send them.
Respondent argues that, in light of the stipulations of facts in
which petitioner admits to receiving the disputed income, the
only issues in dispute are the additions to tax and penalties.
The parties stipulated that for 1996 and 1997, petitioner
received payments for the sale of stocks/bonds and interest
income from National Financial Services Co., which form the basis
of the adjustments determined in the notice of deficiency. The
parties also stipulated that for 2000, petitioner received
payments from the U.S. Postal Service for wages and payments for
the sale of stocks/bonds and interest income from National
Financial Services Co., which form the basis of the adjustments
determined in the notice of deficiency.
Rule 91(e) provides that a stipulation is treated “as a
conclusive admission by the parties to the stipulation” and shall
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