Banat v. Commissioner

SUMMARY ORDER

Robert Banat, pro se, appeals from the judgment of the United States Tax Court (Halpern, A.L.J.) imposing sanctions of $2000 pursuant to I.R.C. § 6673. In March 1999, Banat petitioned the tax court to disallow the IRS’s assessment of tax liability in the amount of $41,372.42 for 1999, arguing that the payment of income tax was voluntary. The IRS moved for summary judgment and, pursuant to I.R.C. § 6673, moved for sanctions against Banat on the ground that the argument was frivolous. The tax court granted the IRS’s motion for summary judgment and, after a hearing, levied sanctions…