- 10 - petitioner may have received, a minimal amount of research would have demonstrated the frivolousness of his arguments and that these arguments repeatedly have been rejected by the courts. See, e.g., Brunner v. Commissioner, T.C. Memo. 2004-187, affd. per curiam __ Fed. Appx. __ (3d Cir., July 21, 2005). Furthermore, petitioner admitted that the joint returns for the prior years 1998 and 1999 were accurate and correct. This admission conflicts with his alleged “beliefs” as to filing returns for 2000 and 2001. At trial, the Court advised and admonished petitioner that the Court, the U.S. Court of Appeals for the Fifth Circuit, and the other U.S. Courts of Appeals previously and repeatedly had rejected the arguments espoused by petitioner and had ruled that his arguments were frivolous. Petitioner stated that he was aware that some of the arguments that he raised had been ruled on and rejected by the courts. Having had the opportunity to observe petitioner, we find petitioner’s claims that he did not “believe” he was required to file returns, that he did not owe the deficiencies or additions to tax, and that he relied on “experts” for the years in issue not credible. Petitioner’s failure to file was not due to reasonable cause; his failure to file was due to willful neglect. Accordingly, we sustain respondent’s determinations thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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