While Reg Section 1.6662-2(c) prevents double-chopping for offenses per Section 6662(a) (“For example, if a portion of an underpayment of tax required to be shown on a return is attributable both to negligence and a substantial understatement of income tax, the maximum accuracy-related penalty is 20 percent of such portion”), there’s no such limit for frivolity.

Anthony Dwayne Williams, Docket No. 10275-23L, filed 7/21/24, gets a Section 6702(a) frivolous submission chop ($5K) confirmed, with a $2500 Section 6673 added at no extra charge by STJ Diana L. (“Sidewalks of New York”) Leyden. Anthony Dwayne led off with an all-zeros 1040 MFJ, and played the Subtitle-A-vs.-Subtitle-C wages gambit with Appeals and then with STJ Di, despite warnings that this move is a loser.

Note the warnings given before the Section 6673 chop is imposed. Frivolites would do well to heed these.