Loran J. Forbes - Page 5

                                        - 5 -                                         
          clear statement of error and contained “nothing more than                   
          frivolous rhetoric and legalistic gibberish”).                              
               Respondent also requests that this Court impose a penalty              
          pursuant to section 6673 because petitioner has instituted the              
          proceeding primarily for delay.  Respondent further contends that           
          petitioner’s position is groundless or frivolous, and that                  
          petitioner filed this petition as a protest to paying income                
          taxes.                                                                      
               Section 6673(a)(1) provides that this Court may require a              
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000 whenever it appears that:  (1) The taxpayer instituted or           
          maintained the proceedings primarily for delay; (2) the                     
          taxpayer’s position in the proceeding is groundless or frivolous;           
          or (3) the taxpayer unreasonably failed to pursue available                 
          administrative remedies.                                                    
               Petitioner has been notified repeatedly that this Court                
          might impose a penalty pursuant to section 6673(a)(1) if he                 
          continued to assert frivolous arguments.  Petitioner lodged with            
          the Court what he captioned a “Commercial notice of                         
          administrative judgment by estoppel with respect to notice of               
          international commercial claim within the admiralty                         
          administrative remedy agreement/contract file number LJF09092004            
          & UCC financing statement file number 05-7017217898” (commercial            
          notice).  Attached to the commercial notice was a letter from the           






Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011