- 17 -
Commissioner, 102 T.C. 596, 614 (1994); Stamos v. Commissioner,
95 T.C. 624, 638 (1990), affd. without published opinion 956 F.2d
1168 (9th Cir. 1992).
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), this
Court issued a stern warning to taxpayers concerning the
imposition of a penalty under section 6673(a) on those taxpayers
who abused the availability of the protections offered by
sections 6320 and 6330 by instituting actions merely for purposes
of delay or by taking frivolous or groundless positions in such
actions. See Kemper v. Commissioner, supra.
Petitioner's essential position in this case is that he owes
no Federal income taxes despite having received over a half a
million dollars in wages and, according to information returns
that have not been legitimately disputed, more than $600,000 in
proceeds from securities trading. Petitioner further invents
numerous groundless claims to defeat respondent's collection of
duly assessed taxes. Petitioner's position is patently
frivolous. His tax protester arguments persuade us that he
invoked the section 6330 protections in bad faith. Respondent's
motion for summary judgment and to impose a penalty put
petitioner on effective warning that section 6673 penalties might
be imposed. Petitioner nonetheless persisted in his course of
conduct, as evidenced by the tax protester rhetoric in his
response to respondent's motion. Petitioner has merely wasted
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011