Kevin M. Moore - Page 5
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duty to file income tax returns--have no merit and are frivolous.
The revenue ruling, under the heading “CIVIL AND CRIMINAL
PENALTIES”, notes that in addition to several other potential
penalties, taxpayers may be liable for “a penalty of up to
$25,000 under section 6673 if the taxpayer makes frivolous
arguments in the United States Tax Court.” Id., 2006-1 C.B. at
746. On the face of the revenue ruling petitioner wrote that he
had read the revenue ruling. Petitioner attached a document
containing frivolous and groundless arguments to the revenue
On August 3, 2006, respondent issued a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330 (notice of determination) to petitioner regarding his
1997, 1998, 1999, 2000, 2001, and 2002 tax years. In the notice
of determination, respondent determined that the proposed
collection action was appropriate, petitioner failed to submit a
viable collection alternative, and collection should proceed. In
an attachment to the notice of determination, respondent referred
petitioner to “The Truth About Frivolous Tax Arguments” and
provided an Internet address to access the document.
On May 16, 2007, the Court held a trial in this matter.
That same day, the Court filed respondent’s and petitioner’s
pretrial memoranda. In his pretrial memorandum, petitioner
stated that he did not intend to call any witnesses.
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Last modified: November 10, 2007