Wayne Curtis Siron - Page 14

                                       - 14 -                                         
          continued making frivolous arguments.  As noted above, in July of           
          2005, respondent’s counsel 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 penalty on the taxpayer pursuant to section             
          6673.  Additionally, in a letter to petitioner dated August 25,             
          2005, respondent’s counsel informed petitioner that respondent              
          would request that the Court impose a section 6673 penalty if               
          petitioner persisted in raising frivolous arguments.  As noted              
          above, respondent filed a motion for a section 6673 penalty at              
          trial.                                                                      
               Moreover, the record demonstrates that petitioner instituted           
          proceedings before this Court primarily for delay.  Petitioner              
          initially designated Kansas City as the place of trial despite              
          his residence in South Carolina throughout the proceedings.                 
          Petitioner refused to agree to respondent’s proposed stipulation            
          of facts, based upon information provided by petitioner, despite            
          the efforts of respondent’s counsel to accommodate all of                   
          petitioner’s specific complaints.                                           
               For the foregoing reasons, we conclude that petitioner has             
          intentionally made frivolous arguments in these proceedings and             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011