- 4 - 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 thesePage: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011