Alex B. Rhodes, Jr. - Page 14
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In Rhodes v. Commissioner, T.C. Memo. 2003-133, the Tax
Court imposed a penalty of $2,000 on petitioner pursuant to
section 6673(a)(1) because petitioner had advanced frivolous
arguments. Before trial in the instant case, the Court warned
petitioner on seven occasions that it would impose a penalty
under section 6673(a)(1) if he continued to advance frivolous
arguments. At trial, the Court also warned petitioner on
numerous occasions that if he continued to advance frivolous
arguments, it would impose a penalty under section 6673(a)(1).
Despite the warnings of the Court, petitioner continued to
assert groundless arguments. Under the circumstances, the Court
will, on its own motion, impose a penalty of $15,000 on
petitioner pursuant to section 6673(a)(1).
In reaching our holdings, we have considered all arguments
made, and, to the extent not mentioned, we conclude that they are
moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: November 10, 2007