Gillespie v. Comm'r
United States Tax Court
These cases brought pursuant to sec. 6330, I.R.C., are before the Court to determine whether Ps must pay penalties pursuant to sec. 6673(a)(1), I.R.C., for instituting procedures primarily for delay, etc., and whether counsel must pay R's excess counsel fees pursuant to sec. 6673(a)(2), I.R.C., for unreasonably and vexatiously multiplying the proceedings. 1. Held: Ps penalized pursuant to sec. 6673(a)(1), I.R.C., for instituting and maintaining proceedings primarily for…
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These cases brought pursuant to sec. 6330, I.R.C., are before the Court to determine whether Ps must pay penalties pursuant to sec. 6673(a)(1), I.R.C., for instituting procedures primarily for delay, etc., and whether counsel must pay R's excess counsel fees pursuant to sec. 6673(a)(2), I.R.C., for unreasonably and vexatiously multiplying the proceedings. 1. Held: Ps penalized pursuant to sec. 6673(a)(1), I.R.C., for instituting and maintaining proceedings primarily for delay, making frivolous arguments and taking groundless positions, and unreasonably failing to pursue available…
1Opinion of the Court
ROBERT AND INES M. GILLESPIE, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Gillespie v. Comm'r
Nos. 3405-05L, 3489-05L, 3490-05L
United States Tax Court
T.C. Memo 2007-202; 2007 Tax Ct. Memo LEXIS 205; 94 T.C.M. (CCH) 91;
July 24, 2007, Filed
These cases brought pursuant to sec. 6330, I.R.C., are before the Court to determine whether Ps must pay penalties pursuant to sec. 6673(a)(1), I.R.C., for instituting procedures primarily for delay, etc., and whether counsel must pay R's excess counsel fees pursuant to sec. 6673(a)(2), I.R.C., for unreasonably and vexatiously…
2Cases cited13 opinions
- Norman E. Coleman v. Commissioner of Internal Revenue, Gary Holder v. Secretary of the Treasury and United States of AmericaCourt of Appeals for the Seventh Circuit · 1986
- Lunsford v. Comm'rUnited States Tax Court · 2001
- In re TCI Ltd.Court of Appeals for the Seventh Circuit · 1985
- Nestor v. Comm'rUnited States Tax Court · 2002
- Nicklaus v. Comm'rUnited States Tax Court · 2001
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