Wilson D. Watson - Page 27




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          119 T.C. 285, 295 (2002).  “A taxpayer’s position is frivolous if           
          it is contrary to established law and unsupported by a reasoned,            
          colorable argument for [a] change in the law.”  Id. at 287.  “The           
          inquiry is objective.  If a person should have known that his               
          position is groundless, a court may and should impose sanctions.”           
          Id.                                                                         
               Petitioner’s arguments that (1) he is not taxable on wages             
          and/or other compensation, and (2) the notices of deficiency for            
          all of the years in issue are invalid, are shopworn, frivolous,             
          tax-protester arguments that are contrary to settled principles             
          of law.  That petitioner made the former argument without                   
          analysis or serious thought as to its merit is indicated by the             
          inclusion of the argument in attachments to his returns and in              
          his petitions for 2001 and 2002, years in which petitioner                  
          received no wages or other compensation for services performed              
          during those years.  In addition, respondent’s counsel mailed a             
          letter dated May 5, 2005, to petitioner advising him that he was            
          advancing frivolous arguments and encouraging him “to consult               
          with a reputable tax practitioner before making such arguments in           
          Court.”  Respondent’s counsel attached to his letter excerpts               
          from an IRS publication entitled “The Truth About Frivolous Tax             
          Arguments”, which addresses all of petitioner’s aforementioned              
          arguments and demonstrates that they are contrary to established            
          law.  Under the circumstances, we shall grant respondent’s motion           







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