- 27 - 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 motionPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: November 10, 2007