- 6 -
1998, and that the State Board paid petitioner $323 during 1998.
Respondent’s proposed stipulation of facts referenced the
following documents: (1) The statutory notice of deficiency;
(2) respondent’s letter to petitioner dated June 9, 2005;
(3) petitioner’s letter to respondent dated June 25, 2005; and
(4) respondent’s certified literal transcript for petitioner.
Additionally, respondent provided petitioner with a copy of
respondent’s publication entitled “The Truth About Frivolous Tax
Arguments” and directed petitioner to the publication’s
discussion of penalties that may be imposed on taxpayers who take
frivolous positions. Respondent also provided petitioner with a
copy of Hodges v. Commissioner, T.C. Memo. 2005-168, in which the
Tax Court imposed a section 6673 penalty on the taxpayer for
advancing a frivolous argument.
In a letter to respondent’s counsel dated August 2, 2005,
petitioner stated that any stipulations would be premature until
the completion of the discovery process. Additionally,
petitioner disputed the relevance of Hodges, and the
aforementioned IRS publication.
In a letter to petitioner dated August 25, 2005,
respondent’s counsel informed petitioner that respondent would
request that the Court impose a penalty pursuant to section 6673
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011