Linda L. Pool - Page 9

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               Accordingly, we conclude that respondent did not abuse his             
          discretion, and we sustain respondent’s determination to proceed            
          with collection.                                                            
          III.  Section 6673                                                          
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay to the United States a penalty not to exceed                
          $25,000 if the taxpayer took frivolous or groundless positions in           
          the proceedings or instituted the proceedings primarily for                 
          delay.  A position maintained by the taxpayer is “frivolous”                
          where it is “contrary to established law and unsupported by a               
          reasoned, colorable argument for change in the law.”  Coleman v.            
          Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); see also Hansen v.           
          Commissioner, 820 F.2d 1464, 1470 (9th Cir. 1987) (section 6673             
          penalty upheld because taxpayer should have known claim was                 
          frivolous).                                                                 
               Petitioner has advanced shopworn arguments characteristic of           
          tax-protester rhetoric that has been universally rejected by this           
          and other courts.  Wilcox v. Commissioner, 848 F.2d 1007 (9th               
          Cir. 1988), affg. T.C. Memo. 1987-225; Carter v. Commissioner,              
          784 F.2d 1006, 1009 (9th Cir. 1986).  We will not painstakingly             
          address petitioner’s assertions “with somber reasoning and                  
          copious citation of precedent; to do so might suggest that these            
          arguments have some colorable merit.”  Crain v. Commissioner, 737           
          F.2d 1417, 1417 (5th Cir. 1984).  Petitioner was warned several             






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