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general circulation, UCC financing statements, and 58 pages of
tax protester information by Larken Rose.3
Respondent determined that petitioner had a $13,676.50
deficiency and had $7,232 tax withheld, leaving a balance due of
$6,444.50.
During informal discovery, respondent wrote petitioner and
stated, inter alia, that petitioner’s arguments were frivolous
and that he might be subject to a penalty under section 6673.
Respondent again warned petitioner about his potential liability
for a penalty under section 6673 in the amendment to answer and
in respondent’s pretrial memorandum.
OPINION
A. Whether Petitioner Is Liable for Income Tax for 2002 in the
Amount Determined by Respondent
Petitioner contends that he is not liable for income tax for
2002 in the amount determined by respondent. We disagree.
Petitioner stipulated that he received wages, interest,
savings bond income, and distributions in 2002 as determined by
respondent. However, he continues to contend that those items
are not taxable for reasons provided in the statement that he
filed in lieu of a Form 1040. Petitioner’s arguments are
frivolous, and we perceive no need to refute them with somber
3 Larken Rose was sentenced to 15 months in prison for not
filing returns and advancing frivolous arguments. See United
States v. Rose, 2005 WL 3216739 (E.D. Pa., Nov. 28, 2005).
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