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4340, Certificate of Assessment, are annexed
for the period in dispute;
c) A copy of Section 6673 of the I.R.C., showing
that the Tax Court can impose sanctions of up
to $25,000 when a taxpayer institutes litiga-
tion before it primarily for delay or based
on a frivolous position;
d) A copy of the case Davis v. Comm., T.C. Memo
[sic] 2001-87, in which it shows that the
court imposed sanctions of $4,000 against the
taxpayer for raising frivolous arguments in a
CDP case;
e) A copy of the case Perry v. Comm., T.C. Memo
[sic] 2002-165, in which the court imposed
sanctions of $2,500 against the taxpayer for
raising frivolous arguments in a CDP case;
* * * * * * *
Upon receipt of the first court opinion, he stated the
courts were a separate issue and when Appeals tried to
explain that the court could impose sanctions, he
stated that would be like “squeezing the turnip.”
The taxpayer was asked if he were [sic] interested in
collection alternatives such as an offer in compromise,
or an installment agreement, and was reminded that all
returns due to date must be appropriately filed for an
offer to be considered, or for an installment agree-
ment. According to IRS computer records, the taxpayers
have not filed returns for 2000-2001. The taxpayer
claims the returns have been filed showing zero income.
He was asked if he had wages and he said yes, but
stated he did not believe that wages were taxable
income and he was unwilling to discuss collection
alternatives. Collection issues could not be discussed
with Rosann Keown as she did not attend the hearing.
The taxpayer raised no non-filer issues. The informa-
tion previously submitted by the taxpayers was re-
viewed, and Rosann Keown raised no non-filer issues.
Balancing the Need for Efficient Collection with Tax-
payer Concerns
The requirements of all applicable laws and administra-
tive procedures have been met. The taxpayers received
their required notices. At the hearing, Appeals raised
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Last modified: May 25, 2011