Judge Patrick J. (“Scholar Pat”) Urda sets forth is policy with respect to frivolites. In this case it’s Louis U. Giannini and Dawn M. Giannini, T. C. Memo. 2022-65, filed 6/23/22, but Lou does fess up to his USPS salary and wages, even though he doesn’t spell all that well. It’s Dawn, whose IT wages from the private sector the Gianninis claim is non-taxable, with the usual protester jive.

Lou and Dawn get four (count ’em, four) pages of “somber reasoning and copious citation of precedent,” apparently because they’re newbies to frivolity.

Notwithstanding their rookie status, Lou and Dawn get the yellow card from Scholar Pat.

“Pursuant to section 6673(a)(1), we have the authority to impose a penalty of up to $25,000 on a taxpayer who pursues a position that is frivolous or groundless. The Gianninis seem to be relatively recent converts to the false faith of frivolous tax positions; we have seen no other case in which they have made these types of arguments. We thus choose not to impose a penalty at this time. We caution the Gianninis, however, that should they again profess these or similar arguments, they will face unhappy consequences.” T. C. Memo. 65, at p. 5.