Wayne Curtis Siron - Page 6

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          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            









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