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Pleasurepays · 12-23-2007, 11:16 PM

Monaghan v. Commissioner, T.C. Memo. 2002-16, 83 T.C.M. (CCH) 1102, 1104 (2002) ? the court rejected the taxpayer?s frivolous arguments and imposed sanctions in the amount of $1,500, stating that ?[h]e has caused this Court to waste its limited resources on his erroneous views of the tax law which he should have known are completely without merit.?

Hart v. Commissioner, T.C. Memo. 2001-306, 82 T.C.M. (CCH) 934 (2001) ? the court imposed sanctions in the amount of $15,000 against the taxpayer, because his delaying actions caused the Service and the court to needlessly spend time preparing for the trial and writing the opinion.

Sigerseth v. Commissioner, T.C. Memo.2001-148, 81 T.C.M. (CCH) 1792, 1794 (2001) ? pointing out that this case involving the use of trusts to avoid taxes was ?a waste of limited judicial and administrative resources that could have been devoted to resolving bona fide claims of other taxpayers,? the court imposed a $15,000 penalty.

MatrixInfoSys Trust v. Commissioner, T.C. Memo. 2001-133, 81 T.C.M. (CCH) 1726, 1729 (2001) ? in claiming that his income belonged to his trust, the court stated that the taxpayer had made ?shopworn arguments characteristic of the tax-protester rhetoric that has been universally rejected by this and other courts,? and imposed a $12,500 penalty.

Madge v. Commissioner, T.C. Memo. 2000-370, 80 T.C.M. (CCH) 804 (2000) ? after having warned the taxpayer that continuing with his frivolous arguments ? that he was not a taxpayer, that his income was not taxable, and that only foreign income was taxable ? would likely result in a penalty, the court imposed the maximum $25,000 penalty.

Haines v. Commissioner, T.C. Memo. 2000-126, 79 T.C.M. (CCH) 1844, 1846 (2000) ? stating, ?[p]etitioner knew or should have known that his position was groundless and frivolous, yet he persisted in maintaining this proceeding primarily to impede the proper workings of our judicial system and to delay the payment of his Federal income tax liabilities,? the court imposed a $25,000 penalty.

Sanctions Imposed in Collection Due Process Cases:
Hassell v. Commissioner, T.C. Memo. 2006-196, 92 T.C.M. (CCH) 273 (2006) ? the court imposed sanctions against the taxpayer in the amount of $10,000 for continuing to assert frivolous arguments.

Forbes v. Commissioner, T.C. Memo. 2006-10, 91 T.C.M. (CCH) 672 (2006) - the court imposed a $20,000 sanction against the taxpayer holding the he failed to assert any coherent claims and only raised frivolous arguments

Burke v. Commissioner, 124 T.C. 189 (2005) ? the court imposed a $2,500 penalty against Burke for wasting judicial resources with his frivolous arguments even though Burke abandoned several frivolous arguments at trial.

Carrillo v. Commissioner, T.C. Memo. 2005-290, 90 T.C.M. (CCH) 608 (2005) ? the court imposed a $5,000 sanction against the taxpayers for making frivolous arguments despite being alerted to the potential use of sanctions against them.

Wetzel v. Commissioner, T.C. Memo. 2005-211, 90 T.C.M. (CCH) 266 (2005) ? the court imposed a $15,000 penalty against Wetzel, a professional tax return preparer, for making frivolous arguments because he knew or should have known the arguments were frivolous.

Hamzik v. Commissioner, T.C. Memo. 2004-223, 88 T.C.M. (CCH) 316 (2004) ? the court imposed sanctions of $15,000 against the taxpayer for his insistence in making frivolous arguments subsequent to the court warning him of the likelihood of penalties being imposed.

Aston v. Commissioner, T.C. Memo. 2003-128, 85 T.C.M. (CCH) 1260 ? the court imposed a $25,000 penalty against the taxpayer for continuing to maintain frivolous arguments, despite having been warned in a previous proceeding before the court that those arguments were without merit.

Fink v. Commissioner, T.C. Memo. 2003-61, 85 T.C.M. (CCH) 976, 980 ? the court imposed a $2,000 penalty against the taxpayer for raising ?primarily for delay, frivolous arguments and/or groundless contentions, arguments, and requests, thereby causing the Court to waste its limited resources.?

Eiselstein v. Commissioner, T.C. Memo. 2003-22, 85 T.C.M. (CCH) 794, 796 (2002) ? the court imposed a penalty of $5,000 against the taxpayer for raising ?frivolous tax-protester arguments? and referred to the ?unequivocal warning? issued by the court in Pierson v. Commissioner concerning the imposition of sanctions against taxpayers abusing the protections provided for in sections 6320 and 6330.

Haines v. Commissioner, T.C. Memo. 2003-16, 85 T.C.M. (CCH) 771, 773 (2003) ? the court imposed a penalty of $2,000 against the taxpayers for making ?protester arguments which have, on numerous occasions, been rejected by the courts.?

12-23-2007, 11:16 PM
Pleasurepays BANNED - SUPPORTING TUBES Join Date: Aug 2002 Location: I live in a pile of boogers Posts: 11,913	Monaghan v. Commissioner, T.C. Memo. 2002-16, 83 T.C.M. (CCH) 1102, 1104 (2002) ? the court rejected the taxpayer?s frivolous arguments and imposed sanctions in the amount of $1,500, stating that ?[h]e has caused this Court to waste its limited resources on his erroneous views of the tax law which he should have known are completely without merit.? Hart v. Commissioner, T.C. Memo. 2001-306, 82 T.C.M. (CCH) 934 (2001) ? the court imposed sanctions in the amount of $15,000 against the taxpayer, because his delaying actions caused the Service and the court to needlessly spend time preparing for the trial and writing the opinion. Sigerseth v. Commissioner, T.C. Memo.2001-148, 81 T.C.M. (CCH) 1792, 1794 (2001) ? pointing out that this case involving the use of trusts to avoid taxes was ?a waste of limited judicial and administrative resources that could have been devoted to resolving bona fide claims of other taxpayers,? the court imposed a $15,000 penalty. MatrixInfoSys Trust v. Commissioner, T.C. Memo. 2001-133, 81 T.C.M. (CCH) 1726, 1729 (2001) ? in claiming that his income belonged to his trust, the court stated that the taxpayer had made ?shopworn arguments characteristic of the tax-protester rhetoric that has been universally rejected by this and other courts,? and imposed a $12,500 penalty. Madge v. Commissioner, T.C. Memo. 2000-370, 80 T.C.M. (CCH) 804 (2000) ? after having warned the taxpayer that continuing with his frivolous arguments ? that he was not a taxpayer, that his income was not taxable, and that only foreign income was taxable ? would likely result in a penalty, the court imposed the maximum $25,000 penalty. Haines v. Commissioner, T.C. Memo. 2000-126, 79 T.C.M. (CCH) 1844, 1846 (2000) ? stating, ?[p]etitioner knew or should have known that his position was groundless and frivolous, yet he persisted in maintaining this proceeding primarily to impede the proper workings of our judicial system and to delay the payment of his Federal income tax liabilities,? the court imposed a $25,000 penalty. Sanctions Imposed in Collection Due Process Cases: Hassell v. Commissioner, T.C. Memo. 2006-196, 92 T.C.M. (CCH) 273 (2006) ? the court imposed sanctions against the taxpayer in the amount of $10,000 for continuing to assert frivolous arguments. Forbes v. Commissioner, T.C. Memo. 2006-10, 91 T.C.M. (CCH) 672 (2006) - the court imposed a $20,000 sanction against the taxpayer holding the he failed to assert any coherent claims and only raised frivolous arguments Burke v. Commissioner, 124 T.C. 189 (2005) ? the court imposed a $2,500 penalty against Burke for wasting judicial resources with his frivolous arguments even though Burke abandoned several frivolous arguments at trial. Carrillo v. Commissioner, T.C. Memo. 2005-290, 90 T.C.M. (CCH) 608 (2005) ? the court imposed a $5,000 sanction against the taxpayers for making frivolous arguments despite being alerted to the potential use of sanctions against them. Wetzel v. Commissioner, T.C. Memo. 2005-211, 90 T.C.M. (CCH) 266 (2005) ? the court imposed a $15,000 penalty against Wetzel, a professional tax return preparer, for making frivolous arguments because he knew or should have known the arguments were frivolous. Hamzik v. Commissioner, T.C. Memo. 2004-223, 88 T.C.M. (CCH) 316 (2004) ? the court imposed sanctions of $15,000 against the taxpayer for his insistence in making frivolous arguments subsequent to the court warning him of the likelihood of penalties being imposed. Aston v. Commissioner, T.C. Memo. 2003-128, 85 T.C.M. (CCH) 1260 ? the court imposed a $25,000 penalty against the taxpayer for continuing to maintain frivolous arguments, despite having been warned in a previous proceeding before the court that those arguments were without merit. Fink v. Commissioner, T.C. Memo. 2003-61, 85 T.C.M. (CCH) 976, 980 ? the court imposed a $2,000 penalty against the taxpayer for raising ?primarily for delay, frivolous arguments and/or groundless contentions, arguments, and requests, thereby causing the Court to waste its limited resources.? Eiselstein v. Commissioner, T.C. Memo. 2003-22, 85 T.C.M. (CCH) 794, 796 (2002) ? the court imposed a penalty of $5,000 against the taxpayer for raising ?frivolous tax-protester arguments? and referred to the ?unequivocal warning? issued by the court in Pierson v. Commissioner concerning the imposition of sanctions against taxpayers abusing the protections provided for in sections 6320 and 6330. Haines v. Commissioner, T.C. Memo. 2003-16, 85 T.C.M. (CCH) 771, 773 (2003) ? the court imposed a penalty of $2,000 against the taxpayers for making ?protester arguments which have, on numerous occasions, been rejected by the courts.?