- 8 - frivolous or groundless positions in the proceedings or instituted the proceedings primarily for delay. In the petition, petitioner alleged that the deficiencies determined by respondent are excise taxes. This argument is frivolous and groundless. At trial, petitioner mainly objected to the admission of any evidence that tended to prove that he earned income during the years in issue and sought to impugn the integrity of his former employers by implying that they overstated the income they paid him in order to obtain a fraudulently higher deduction (for compensation paid) on their own tax returns. He feigned lack of memory regarding his earnings during the years in issue even though he admitted working for all the employers who were called as witnesses and that he was paid for services he rendered to those employers. Furthermore, in a home loan application petitioner signed in 2001, petitioner listed his monthly income as $9,625. Petitioner established his pattern of delay early on when he failed to cooperate with respondent. Petitioner failed to meet with or to provide respondent with any information that would have enabled respondent to properly determine petitioner’s tax liability or resolve this case without trial. Furthermore, after asking the Court for additional briefing time at the conclusion of the trial, petitioner failed to file any posttrial briefs. WePage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011