Cynthia P. Bullock - Page 2

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          Inc.  Because this is the third case in which petitioner raised             
          the same or similar arguments, and because she has had prior                
          warning, the Court, on its own motion, is imposing a penalty of             
          $7,500 under section 6673.  Unless otherwise indicated, all                 
          section references are to the Internal Revenue Code in effect for           
          the year in issue, and all Rule references are to the Tax Court             
          Rules of Practice and Procedure.                                            
                                     Background                                       
               Petitioner resided in Florence, Kentucky, at the time that             
          she filed her petition.  In 1999, she and her spouse filed a                
          petition in this Court, docket No. 15381-99, in which they                  
          challenged deficiencies for 1996 and 1997.  Petitioner and her              
          spouse moved to withdraw that petition and failed to amend their            
          petition after having been given an opportunity to do so.  The              
          Court denied the motion to withdraw and granted respondent’s                
          motion to dismiss for failure to state a claim.  On appeal, the             
          Court of Appeals stated, in part:                                           
               even after being given an opportunity to amend their                   
               petition, they raised only frivolous arguments, such as                
               claiming that their income was not “wages” or that                     
               their wages were not taxable income, which have                        
               repeatedly been rejected.  See Wilcox v. Comm’r, 848                   
               F.2d 1007, 1008 (9th Cir. 1988); Perkins v. Comm’r, 746                
               F.2d 1187, 1188 (6th Cir. 1984).  [Bullock v.                          
               Commissioner, 21 Fed. Appx. 272, 273 (6th Cir. 2001).]                 
               In 2004, petitioner filed a petition, docket No. 1530-04,              
          challenging a notice of deficiency sent to her for 2000.                    
          Respondent filed a motion to dismiss for failure to state a claim           





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