Gabriel T. Lewis - Page 8

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          Estate of Ruben v. Commissioner, 33 T.C. 1071, 1072 (1960).                 
               Petitioner did not remit any estimated tax payments for 2002           
          and has not shown that any of the statutory exceptions are                  
          applicable.  Respondent’s determination as to the addition to tax           
          under section 6654(a) is sustained.                                         
          4.   Section 6673 Sanctions                                                 
               As indicated at trial, respondent filed a Motion for                   
          Sanctions to impose a penalty on petitioner pursuant to section             
          6673(a)(1).  Petitioner made frivolous arguments in his petition,           
          at trial, and in a memoranda to this Court.  Petitioner’s brief             
          only made more groundless arguments in response to respondent’s             
          Motion.                                                                     
               Under these circumstances, we see no need to catalog                   
          petitioner’s arguments and painstakingly address them.  As the              
          Court of Appeals for the Fifth Circuit has remarked:  “We                   
          perceive no need to refute these arguments with somber reasoning            
          and copious citation of precedent; to do so might suggest that              
          these arguments have some colorable merit.”  Crain v.                       
          Commissioner, 737 F.2d 1417 (5th Cir. 1984).                                
               Section 6673(a)(1) authorizes the Tax Court to require a               
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000 whenever it appears that proceedings have been instituted           
          or maintained by the taxpayer primarily for delay or that the               
          taxpayer’s position in such proceeding is frivolous or                      






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