While Dodging the Tax

I didn’t blog William A. Llanos, Docket No. 9890-18, filed 10/15/19, when it was decided; it was the usual off-the-bench tax-dodger.

Fortunately for Wm A, though, he filed his petition in William Allen Llanos, 2021 T. C. Memo. 21, filed 2/22/21, before Judge Kerrigan unloaded the aforementioned off-the-bencher, and IRS wasn’t then looking for Section 6673 chops, so no yellow card to Wm A. Wherefore, Wm A dodges the Section 6673 chop this time.

It’s the usual wages-aren’t-taxable frivol, just like the last time. I won’t quote William Blake again; as C. S. Lewis said of the great artist-poet, “I am not at all sure I know what he meant.” But I am entirely sure that persisting in frivolity is not wise.

Here’s Judge Kerrigan’s take.

“Although petitioner did advance frivolous arguments during trial, he agreed to stipulations of facts and raised an argument addressing whether the penalty approval requirement of section 6751(b) was met. This case is not the first time petitioner has raised frivolous arguments before this Court. In Llanos v. Commissioner, T.C. Dkt. No. 9890-18 (Sept. 11, 2019) (bench opinion), read into the record on September 11, 2019, this Court made it clear that petitioner did not make any valid arguments, and the same is true of this case. Since the petition in this case was filed before the trial of petitioner’s previous case, we will warn petitioner, rather than impose sanctions. If petitioner does not abandon his misguided positions, it is very likely that a sanction will be imposed in any future cases before this Court.” 2021 T. C. Memo. 21, at p. 9.

Wm A gets Section 6702 chops, dodges the Section 6673.