Cracking up once more is Steven T. Waltner, joined by Ms. Sarah V. Waltner, in 2015 T. C. Memo. 146, filed 8/6/15. I say “cracking up,” as that was the title of my first account of Steve’s maneuverings; see my blogpost “Cracking Up,” 2/27/14.

Ms. Sarah V. Waltner featured in my blogpost “A Tale of Three Lawyers,” 7/3/14.

At this juncture, lest I be accused of piling on after the whistle, I must quote from the latter blogpost. “I do not indulge in schadenfreude; I find such stuff unworthy of discussion in a high-minded blog like mine. So today’s blogpost is not a gloat over others’ difficulties, but to point the way for my readers, or their respective counsel, to avoid the pitfalls hereinbelow set forth, as my already-on-their-second-bottle-of-2003-Château-Léoville-Poyferré colleagues say.”

Steve and Ms. Sarah V. Waltner are senior-league rounders. Judge Haines catalogues their previous delicitons, and orders their now-or-former attorney, whom I’ll call Donny, to show cause why he should not be mulcted for the cost of the extra trouble and grief he caused the crew at 1111 Constitution Avenue, NW.

And Steve and Ms. Sarah V. Waltner climb another step in the Stairway to the $25K Section 6673 Chop.

“The only issue in Waltner v. Commissioner, T.C. Memo. 2014-35, was whether Mr. Waltner should be subject to a section 6673 sanction because he paid the section 6702 penalty. After a detailed discussion, which we will not reiterate here, we determined the answer was ‘yes’ and imposed a section 6673 penalty of $2,500. Petitioners did not heed our warning in that case and refused to withdraw their frivolous positions in Waltner v. Commissioner, T.C. Memo. 2014-133. As a result, we imposed yet another section 6673 penalty of $5,000 on each petitioner, for a total of $10,000, in that case.

“In this case respondent seeks the maximum section 6673 penalty of $25,000. Despite our repeated warnings that we will not tolerate petitioners’ frivolous positions and our imposition of substantial monetary penalties, we have been unable to dissuade petitioners. Petitioners continued to advance positions in this case which they had already been warned were frivolous. We find a section 6673(a)(1) sanction is warranted and impose a $15,000 penalty in total on petitioners.” 2015 T. C. Memo. 146, at pp. 16-17.