But No Explanation

No, not the 1950s television show, but the name carries weight today, 4/23, even though Tax Court issued no opinions today, and the designated orders don’t give much, barring Joe Insinga, the star of my blogposts “Did Nothing”, 3/13/13, and “A Voyage of Discovery”, 3/30/13. Joe hauls down his battle flag and consents to a dismissal of his whistleblower petition without prejudice today, with no explanation.

So here’s another unexplained phenomenon, a full Section 6673(a) frivolity penalty in Docket No. 5657-10, filed 4/23/13, nailing Laurel Ann Curtis.

Now Laurel Ann has a four-year string of deficiencies going back to 1994, with additions and penalties galore, but why the full-Monty frivolity sanctions, Judge Thornton?  How can we counsel clients without knowing exactly what will cause Tax Court to drop the Big Hammer?

Even where, as here, the frivolous taxpayer doesn’t respond to IRS’ motion for sanctions, Tom Jefferson’s “decent respect to the opinions of mankind” should impel the Court to tell us why.