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will refer to the United States District Court for the Eastern
District of Wisconsin as the District Court and the
aforementioned proceeding as the District Court collection
action.) The records in the instant cases include copies of
various documents that petitioners filed in the District Court
collection action. These documents reflect that petitioners,
prosecuting the case pro sese, raised only frivolous and
groundless arguments. Both petitioners signed the documents
filed with the District Court. Neither petitioner asserted in
the District Court collection action an entitlement to relief
from joint and several liability under section 6015.
On August 11, 2000, the District Court granted the
Government’s motion for summary judgment and entered a judgment
in favor of the United States for unpaid assessed balances for
the taxable years 1981, 1990, and 1992 in the amounts of
$1,924,000.19, $537,514.10, and $193,618.56, respectively.
Petitioners filed an appeal with the Court of Appeals for the
Seventh Circuit. The Court of Appeals affirmed the District
Court’s judgment and granted the Government’s motion for
sanctions against petitioners for prosecuting a frivolous appeal.
United States v. Thurner, 21 Fed. Appx. 477 (7th Cir. 2001). The
Supreme Court later denied petitioners’ petition for writ of
certiorari.
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Last modified: May 25, 2011