Spoiler alert: it isn’t happy. Merrie P. Wycoff, T. C. Memo. 2024-37, filed 3/28/24, loses her CDP, and the epistolary barrage she directed after her attorney bailed gets her a very modest Section 6673 frivolity chop from Judge Albert G (“Scholar Al”) Lauber.

“The purpose of section 6673 is to compel taxpayers to think and to conform their conduct to settled principles before they file and litigate. This is because frivolous and groundless claims ‘divert the Court’s time, energy, and resources away from more serious claims and increase the needless costs imposed on other litigants.’  With a view to deterring abuse of judicial and IRS resources, this Court must exercise its discretion to determine when a penalty under section 6673 is appropriate, and in what amount.

“Petitioner has continued her pattern of frivolous filings despite our warnings. However, her filings display confusion and make it clear that she has suffered from loss of representation by her former counsel. We will therefore exercise our discretion to impose a modest penalty of $250.” T. C. Memo. 2024-37, at p. 9. (Citations omitted).

Merrie was here back in 2014; see my blogpost “Open and Shut,” 1/13/14, and again in 2017; see my blogpost “The Boss As Consultant,” 10/16/17. In the meantime, Merrie’s spouse Jeff died and their business cratered. But Merrie’s attempt to get CNC founders when she lays off $350K, claiming a loan she can’t prove, $247K in the bank, and $1.8 million in equity in her home.

The deficiencies here are older than most whiskey I can afford, and the interest must definitely be a lot more than I can afford.