Robert B. Keenan - Page 13

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          frivolous and groundless litigation in this Court, and the                  
          warnings he has received in previous administrative and judicial            
          proceedings regarding the consequences of pursuing frivolous and            
          groundless arguments.  Petitioner repeatedly has failed to file             
          Federal income tax returns.  He participated in administrative              
          proceedings before the Internal Revenue Service and filed several           
          cases in this Court in which he challenged the legitimacy of the            
          tax system and repeatedly questioned his obligation to file tax             
          returns.  See Keenan v. Commissioner, T.C. Memo. 2006-45; Keenan            
          v. Commissioner, T.C. Memo. 1998-388.  During the previous                  
          administrative and judicial proceedings and the section 6330                
          hearing in this case, petitioner was warned of the consequences             
          that may attach to his conduct challenging the tax system.  See,            
          e.g., Keenan v. Commissioner, T.C. Memo. 2006-45.  Despite the              
          warnings, petitioner has continued to challenge the validity of             
          the tax system and of the assessments at issue in this case.                
          Consequently, we shall require petitioner to pay to the United              
          States a penalty under section 6673(a)(1) of $15,000.                       
               Other arguments raised by petitioner have been considered              
          and are rejected as meritless.                                              
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                







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