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groundless, and frivolous. Section 1 imposes an income tax on
petitioner’s taxable income. Section 63 defines taxable income
as gross income minus deductions. Section 61 defines gross
income as including wages and the other categories of receipts
admitted by petitioner. Arguments to the contrary have been
consistently rejected and characterized as frivolous in
innumerable cases. No further discussion of them is merited.
See Connor v. Commissioner, 770 F.2d 17, 20 (2d Cir. 1985); Crain
v. Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984); Cabirac v.
Commissioner, 120 T.C. 163, 167 (2003). Petitioner’s arguments
concerning respondent’s procedures are similarly frivolous and
lacking in merit.
Section 6673 provides:
SEC. 6673(a). Tax Court Proceedings.--
(1) Procedures instituted primarily for delay,
etc.--Whenever it appears to the Tax Court that--
(A) proceedings before it have been
instituted or maintained by the taxpayer primarily
for delay,
(B) the taxpayer’s position in such
proceeding is frivolous or groundless, or
(C) the taxpayer unreasonably failed to
pursue available administrative remedies,
the Tax Court, in its decision, may require the
taxpayer to pay to the United States a penalty not in
excess of $25,000.
Notwithstanding prior warnings, petitioner has been undeterred.
A penalty shall be awarded to the United States in each of these
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Last modified: May 25, 2011