Attorney-at-Law

GOING FOR THE GUINNESS

In Uncategorized on 06/10/2021 at 13:24

No, not the pride of the St. James Gate Brewery, Dublin, best had at The Galway Hooker public house in Heuston Railway Station (eleven minute walk from the brewery; the nearest pub, freshest draft. Trust me.). The statistical empire the brew inspired forms the predicate for today’s episode of Gregory J. Podlucky & Karla S. Podlucky, Docket No. 435-17, filed 6/10/21.

Greg’s been here before, of course; I get ’em all, every wit, wag, wiseacre, wiseguy, and rounder swims into my ken, eventually. See my blogpost “Work Ethic,” 6/26/19.

You’ll note that it’s been a while since Greg was here. Judge Albert G (“Scholar Al”) Lauber explains. “In 2009 petitioner husband was indicted in the U.S. District Court for the Western District of Pennsylvania for mail fraud, conspiracy to commit money laundering, and attempting to evade or defeat tax for 2003-2006, in violation of I.R.C. § 7201. In 2011 petitioner husband pleaded guilty to these charges. He was sentenced to a lengthy term of imprisonment.” Order, at p. 1. So Greg’s Tax Court trial has been continued (that means “adjourned,” to  us State courtiers) a couple times (hi, Judge Holmes), because of Greg’s incarceration.

But Greg has nowise been idle. Like other residents of slammerdom, Greg just churns out frivolities; apparently he has little else to do. “Largely because of these gratuitous filings, the docket in this case already has more than 180 entries.” Order, at p. 2. Why not? If the maximum Section 6673 frivolity chop is $25K, your total deficiencies plus fraud chops are north of $8 million, and you’ve got plenty of time on your hands, you might as well seek an entry in Guinness World Records for whatever year you get out of the clink.

You can read Greg’s further productions for yourself. Greg has apparently cruised every protester-defier site, mastered drag-and-drop, and keeps on rolling along.

Meantime, Judge Scholar Al bounces Greg’s latest production (number 181), with a warning that maybe should have been given before now. “I.R.C. § 6673(a)(1) authorizes this Court to require a taxpayer to pay to the United States a penalty of up to $25,000 if it appears to the Court that the taxpayer has instituted or maintained proceedings “primarily for delay” or has taken a posi-tion that “is frivolous or groundless.” Petitioner husband’s submissions to this Court to date have included numerous frivolous statements and positions. We warn petitioner husband that he risks a significant penalty if he continues on this path. See, e.g., Briggs v. Commissioner, T.C. Memo. 2016-86 (imposing penalty of $3,000); Balice v. Commissioner, T.C. Memo. 2015-46 (imposing penalty of $25,000).” Order, at p. 2.

I don’t know why I didn’t blog Briggs, but I can’t find the T. C. Memo. on Google, and the DAWSONized Tax Court website is, as usual, utterly worthless; there is no way to search for opinions. For the story of Mike Balice, see my blogpost “The Jolly Rounder,” 3 /16/15.

What price a $25K chop when Guinness immortality is in view?

Edited to add, 7/21/21: Stephen H. Briggs and Patricia S. Briggs, 2016 T. C. Memo. 86, filed 5/2/86, is online at last. Turns out Steve and Pat were in Tax Court back in 2014, protesting, and got chopped with $500 “as a warning.”

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