John H. Webster - Page 7

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          an unwillingness on the part of petitioner to respect the tax               
          laws of the United States.  Petitioner has had a fair warning               
          that penalties would be imposed if he continued to make frivolous           
          arguments.  Accordingly, we shall impose a penalty on petitioner            
          pursuant to section 6673 in the amount of $2,500.                           
               To the extent not herein discussed, we have considered the             
          parties’ other arguments and found them to be irrelevant or                 
          meritless.                                                                  
               To reflect the foregoing,                                              
                                                  An appropriate order and            
                                             decision will be entered.                



























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