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alleged failure to comply with the PRA may bar the assessment and
collection of Federal income tax); Aldrich v. Commissioner, T.C.
Memo. 1993-290; McDougall v. Commissioner, T.C. Memo. 1992-683,
affd. without published opinion 15 F.3d 1087 (9th Cir. 1993).
Nevertheless, in light of the newness at the time of trial in
this case of the Tenth Circuit’s decision in Pond v.
Commissioner, 211 Fed. Appx. 749 (10th Cir. 2007), affg. T.C.
Memo. 2005-255, which petitioner appears to have misunderstood,
we shall exercise great restraint and shall not this time impose
a penalty under section 6673(a)(1). Petitioner is warned,
however, that we shall not be so inclined should he again advance
before the Court arguments, incorrectly relying on Pond v.
Commissioner, supra, as frivolous as those advanced in these
cases.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing,
Appropriate decisions
will be entered.
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Last modified: November 10, 2007