Carey K. Parker II - Page 9

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          II. Section 6673                                                            
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay to the United States a penalty not to exceed                
          $25,000 if the taxpayer took frivolous or groundless positions in           
          the proceedings or instituted the proceedings primarily for                 
          delay.  A position maintained by the taxpayer is “frivolous”                
          where “it is contrary to established law and unsupported by a               
          reasoned, colorable argument for change in the law.”  Coleman v.            
          Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); see also Hansen v.           
          Commissioner, 820 F.2d 1464, 1470 (9th Cir. 1987) (section 6673             
          penalty upheld because taxpayer should have known claim was                 
          frivolous).                                                                 
               Petitioner’s petition is replete with tax-protester                    
          rhetoric.  Petitioner has advanced shopworn arguments                       
          characteristic of tax-protester rhetoric that has been                      
          universally rejected by this and other courts.  Wilcox v.                   
          Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo.               
          1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir.             
          1986).                                                                      
               Additionally, it is obvious to the Court that petitioner               
          litigated this case primarily for delay.  Petitioner was advised            
          of our opinion in Pierson v. Commissioner, supra, and that he               
          could not litigate respondent’s decision in court.                          







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