Gregory Eugene Thompson - Page 11




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          IV. Section 6673 Penalty                                                    
               We now consider whether petitioner should be held liable for           
          a penalty under section 6673.  We take this opportunity to warn             
          petitioner that we are authorized to impose a penalty of up to              
          $25,000 on a taxpayer if the Court finds, among other things,               
          that the taxpayer’s position in proceedings is frivolous or                 
          groundless.  A taxpayer’s position is frivolous if it is contrary           
          to established law and unsupported by a reasoned, colorable                 
          argument for change in the law.6  See Coleman v. Commissioner,              
          791 F.2d 68, 71 (7th Cir. 1986); see also Hansen v. Commissioner,           
          820 F.2d 1464, 1470 (9th Cir. 1987); Nis Family Trust v.                    
          Commissioner, 115 T.C. 523, 544 (2000).                                     
               The purpose of section 6673 is to compel taxpayers to think            
          and conform their conduct to settled tax principles.  Coleman v.            
          Commissioner, supra; see also Takaba v. Commissioner, 119 T.C.              
          285, 295 (2002).  The section is a penalty provision intended to            
          deter and penalize frivolous claims and positions in proceedings            
          before this Court.                                                          
               Petitioner makes numerous frivolous arguments on brief.                
          Petitioner asserts that none of his income is taxable, arguing              
          that wages are not income and no person is liable for income tax.           
          Though we do not impose a penalty here, nor does respondent ask             
          us to impose a section 6673 penalty, we caution petitioner that             
          should he bring similar arguments before this Court in the                  

               6We have jurisdiction to hear the case notwithstanding that            
          we find petitioner’s arguments frivolous.  Petitioner’s                     
          assertions to the contrary are incorrect.                                   





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