William M. Leggett - Page 11

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               Respondent, on brief, asserts that the Court should impose a           
          penalty pursuant to section 6673(a)(1).  Petitioner is no                   
          stranger to the Court or to the section 6673 penalty.  Petitioner           
          raised frivolous arguments in his first trial which involved the            
          taxable years in issue here of 1994, 1995, and 1996.  Petitioner            
          made similar arguments in a 2005 trial, regarding a deficiency              
          and additions to tax for his 2001 taxable year, and was ordered             
          to pay $5,000 to respondent for again asserting frivolous                   
          arguments.  Leggett v. Commissioner, supra.  Despite repeated               
          warnings by the Court in petitioner’s two previous trials and the           
          imposition of a section 6673 penalty, petitioner repeated the               
          same frivolous arguments in this current case although he did not           
          dwell on them at trial.  The Court is convinced that petitioner’s           
          positions are frivolous and made at least in part for delay.                
          Therefore, the Court concludes that a penalty of $2,500 should be           
          imposed on petitioner.                                                      
               The Court has considered all of petitioner’s contentions,              
          arguments, requests, and statements.  To the extent not discussed           
          herein, we conclude that they are meritless, moot, or irrelevant.           
               To reflect the foregoing,                                              

                                                  An appropriate decision             
                                             will be entered.                         








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