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Petitioner filed two prior cases in this Court (and one
subsequent case). Docket No. 3112-03 involved petitioner’s
Federal income tax liability for 1997, 1998, and 2000. In an
oral opinion rendered September 21, 2004, the Court sustained
deficiencies and additions to tax under sections 6651(a)(1) and
6654(a) for each of those years. In addition, the Court stated:
I am also granting * * * the government’s motion
for a penalty under Section 6673. As I did yesterday,
I will make it in the relatively low amount of $3,000,
but noting that the Court’s official records show that
Mr. Silver has filed a case docketed in the ‘04 year, I
urge him to reconsider any positions he takes that may
result in an increase in penalties for making similar
arguments in that case when it’s called next year about
this time.
The reference to “yesterday” was to the Court’s oral opinion
rendered on September 20, 2004, in docket No. 15785-02L, a case
in which petitioner contested collection efforts with respect to
his tax liability for 1995 and 1996. The Court, in docket No.
15785-02L, explained that petitioner’s arguments in that case
were frivolous, and the Court granted a motion for sanctions
under section 6673 in the amount of $3,000.
OPINION
In the petition in this case, petitioner alleged that he
“did not receive any taxable income from any taxable source or
activity during the years 2001 and 2002.” Petitioner also
alleged that he would be entitled to deductions, allowances, and
credits, but he did not specify the nature or amounts of any such
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Last modified: May 25, 2011