Davis 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: P husband penalized pursuant to sec. 6673(a)(1), I.R.C., for instituting and maintaining proceedings primarily…
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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: P husband 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
LAURA K. DAVIS, ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Davis v. Comm'r
Nos. 144-05L, 145-05L, 146-05L, 147-05L, 149-05L
United States Tax Court
T.C. Memo 2007-201; 2007 Tax Ct. Memo LEXIS 204; 94 T.C.M. (CCH) 81;
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 multiplying…
2Cases cited13 opinions
- Lunsford v. Comm'rUnited States Tax Court · 2001
- In re TCI Ltd.Court of Appeals for the Seventh Circuit · 1985
- Red Carpet Studios Division of Source Advantage, Ltd. v. SaterCourt of Appeals for the Sixth Circuit · 2006
- Nestor v. Comm'rUnited States Tax Court · 2002
- United States v. Melvin D. Wallace and Arthur M. LevinCourt of Appeals for the D.C. Circuit · 1992
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