Peter T. Storaasli - Page 23

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          liability for the section 6654 addition to tax applies.                     
          Consequently, we hold petitioner liable for the section 6654(a)             
          additions to tax.                                                           
          IV. Section 6673 Penalty                                                    
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay the United States a penalty, not to exceed                  
          $25,000, if it appears that the taxpayer has instituted or                  
          maintained a proceeding primarily for delay or that the                     
          taxpayer’s position is frivolous or groundless.  A taxpayer’s               
          position is frivolous or groundless if it is contrary to                    
          established law and unsupported by a reasoned, colorable argument           
          for change in the law.  Williams v. Commissioner, 114 T.C. 136,             
          144 (2000) (citing Coleman v. Commissioner, 791 F.2d 68, 71 (7th            
          Cir. 1986)).                                                                
               Petitioner’s arguments regarding the constitutionality of              
          the Federal tax laws, the authority of the Federal Government to            
          impose an income tax, and the tax treatment of personal labor are           
          contrary to well-established law.  We shall not address these               
          assertions “with somber reasoning and copious citation of                   
          precedent; to do so might suggest that these arguments have some            
          colorable merit.”  Crain v. Commissioner, 737 F.2d 1417, 1417               
          (5th Cir. 1984).  Although we struck similar tax-protester                  
          arguments from the petition and repeatedly admonished petitioner            
          at trial that by making these arguments he risked incurring a               






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