Takaba v. Comm'r
United States Tax Court
This case is before the Court to consider whether P must pay a penalty pursuant to sec. 6673(a)(1), I.R.C., and whether P's counsel must pay certain of R's costs pursuant to sec. 6673(a)(2), I.R.C.
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This case is before the Court to consider whether P must pay a penalty pursuant to sec. 6673(a)(1), I.R.C., and whether P's counsel must pay certain of R's costs pursuant to sec. 6673(a)(2), I.R.C. P, initially pro se, made frivolous arguments, which were continued by P's counsel, who further advocated the frivolous argument that the regulations under sec. 861, I.R.C., establish that, although P is a U.S. citizen, P's income in the form of remuneration for services and bank interest received from sources within the United States is not subject to tax. 1. Held: P is liable for a penalty under…
1Opinion of the Court
BRIAN G. TAKABA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Takaba v. Comm'r
No. 5454-99
United States Tax Court
119 T.C. 285; 2002 U.S. Tax Ct. LEXIS 56; 119 T.C. No. 18;
December 16, 2002, Filed
Court imposed on petitioner a penalty of $ 15,000 and on Mr. Sulla a liability of $ 10,500.
This case is before the Court to consider whether P must pay a
penalty pursuant to sec. 6673(a)(1), I.R.C., and whether P's
counsel must pay certain of R's costs pursuant to sec.
6673(a)(2), I.R.C. P, initially pro se, made frivolous
arguments, which were continued by P's counsel, who further
advocated…
2Cases cited32 opinions
- New York Times Co. v. SullivanSupreme Court of the United States · 1964
- Ernst & Ernst v. HochfelderSupreme Court of the United States · 1976
- St. Amant v. ThompsonSupreme Court of the United States · 1968
- In Re Silicon Graphics Inc. Securities Litigation. Edmund J. Janas v. Edward R. McCracken Michael Ramsay Robert K. Burgess Thomas J. Oswald Teruyasu Sekimoto Forest Baskett Stephen Goggiano William M. Kelly Lucille Shapiro Silicon Graphics, Inc., Deanna Brody Andrea S. Donald Israel Buck Ruth Buck Denise Struthers Thomas G. Di Cicco Ira Steven B. Ewall Rosalyn Golaine Jerry Krim Mary Anne Beke Herman Grossman Samuel J. Reiner Dennis Lucas v. Edward R. McCracken Michael Ramsay Robert K. Burgess Thomas J. Oswald Teruyasu Sekimoto Forest Baskett Stephen Goggiano William M. Kelly Lucille Shapiro Silicon Graphics, Inc.Court of Appeals for the Ninth Circuit · 1999
- B.K.B., Plaintiff-Appellant-Cross-Appellee v. Maui Police Department, County of Maui, County of Maui, Defendant-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 2002
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