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petitioner on six occasions of the possibility of
imposing a penalty under section 6673(a)(1) if he
continues to advance frivolous arguments. See Orders
dated Nov. 14, 2005; Feb. 8, 2006; Feb. 27, 2006; Mar.
23, 2006; May 30, 2006; and Jul. 11, 2006. For the
seventh time, the Court warns petitioner that it will
impose a penalty of up to $25,000 under section
6673(a)(1) if he continues to advance frivolous
arguments.
At trial, the Court warned petitioner on numerous occasions
that the arguments he was making have been deemed frivolous by
the Court and it has imposed penalties under section 6673 against
taxpayers who raise such arguments. Despite the Court’s
warnings, petitioner continued with the frivolous and groundless
arguments at trial.
OPINION
A. Petitioner’s Federal Income Tax Deficiencies
Throughout this case, petitioner presented tax-protester
arguments to assert he was not liable for Federal income tax
deficiencies as determined in the notices of deficiency for the
years at issue, including: (1) He is not a taxpayer; (2)
respondent has no jurisdiction over him; (3) his wages did not
constitute gross income; and (4) respondent lacks authority to
assert income tax deficiencies. Petitioner’s assertions have
been rejected by this Court and other courts, and “We perceive no
need to refute these arguments with somber reasoning and copious
citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner,
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Last modified: November 10, 2007