Isaiah Israel - Page 7

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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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