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833 F.2d 1538, 1539 (11th Cir. 1987); Sauers v. Commissioner, 771
F.2d 64 (3d Cir. 1985), affg. T.C. Memo. 1984-367; Biermann v.
Commissioner, 769 F.2d 707 (11th Cir. 1985); Waters v.
Commissioner, 764 F.2d 1389 (11th Cir. 1985); Crain v.
Commissioner, 737 F.2d 1417 (5th Cir. 1984); Knighten v.
Commissioner, 702 F.2d 59 (5th Cir. 1983); Lonsdale v.
Commissioner, 661 F.2d 71, 72 (5th Cir. 1981), affg. T.C. Memo.
1981-122; Reading v. Commissioner, supra.
The nature of the items that petitioner was claiming was
disguised on his tax returns. When his explanation was given, it
was apparent that the deductions were erroneous and contrary to
law. He is liable for the accuracy-related penalties under
section 6662. In addition, a penalty under section 6673 in the
amount of $15,000 is appropriate. Petitioner’s arguments were
frivolous. In view of his persistence in the face of contrary
authority and the deception on the face of his returns, we do not
believe that the arguments were made in good faith. See, e.g.,
Sauers v. Commissioner, supra at 68 n.6.
An appropriate order and
decision for respondent will
be entered.
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