- 5 - Service and from the TRW pension plan for 2000 were income and taxable to petitioner. In docket No. 9757-05L, a section 6330 case regarding collection of petitioner’s 1999 tax liability, respondent filed a motion for summary judgment and to impose a penalty under section 6673. In docket No. 9757-05L, petitioner advanced frivolous and groundless arguments, and on March 20, 2006--7 months prior to the trial of the instant case--the Court entered an order and decision granting respondent’s motion to impose a penalty under section 6673 and imposing a penalty of $2,500 pursuant to section 6673. Furthermore, in the case at bar, on May 4, 2006, in an order granting partial summary judgment to respondent, this Court stated: “Petitioner is admonished not to pursue frivolous arguments which have been rejected by both this Court and the Court of Appeals for the Ninth Circuit. Should petitioner continue to pursue those frivolous arguments, this Court will impose a penalty on petitioner under section 6673.” At trial, the Court reminded petitioner of this admonishment. Petitioner stated that he was familiar with section 6673. Petitioner continued to advance frivolous arguments, e.g., the definition of “income” in section 61 “is used in its constitutional sense” and shopworn arguments regarding the 16th Amendment characteristic of tax-protester rhetoric that has beenPage: Previous 1 2 3 4 5 6 NextLast modified: November 10, 2007