- 5 - 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 ruling. 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007