Baseball fans know that hitting for the cycle means a player, in a single game, hits a one-base hit (single), two-base hit (double), three-base hit (triple), and a four-base hit (home run). It is possibly the rarest feat in American professional baseball.
While Brian Dean Swanson, T. C. Memo. 2024-105, filed 11/12/24, has not received a Section 6673 frivolity chop in each increment from zero to $25,000, his record is sufficiently impressive to warrant a Taishoff “Frivolite of the Cycle” award.
“We take judicial notice that the Eleventh Circuit has sanctioned petitioner in the amount of $8,000 at least three separate times for taking such positions and that the Southern District of Georgia has also sanctioned him by permanently enjoining him from filing refund suits in federal court for any tax year in which he has failed to report his wages as income. See Swanson 9, 2023 WL 5605738, at *3; Swanson 6, 2021 WL 4551628, at *2; Swanson 3, 799 F. App’x at 671–72; Swanson 13, 2024 WL 3342503. We take further notice that this Court has sanctioned petitioner in the amount of $15,000 for making frivolous arguments. Transcript of Bench Opinion at 26, Swanson 11, No. 2526-23. As these sanctions appear to have left petitioner undeterred, we will grant respondent’s Motion and impose a penalty of the full $25,000 permitted in the hopes that petitioner will in fact think and conform his conduct to settled principles going forward.” T. C. Memo. 2024-105, at p. 7. (Footnotes omitted, but it’s more about Brian Dean’s appealing ways).
I can only wish Judge Alina I. (“AIM”) Marshall better success than I can myself envision.
But Brian Dean does manage to avoid the Section 6662(a) accuracy/negligence chops. The 1040 he filed isn’t a return, in that it doesn’t provide information reasonably necessary to calculate tax, nor is it a an honest and reasonable attempt to comply with law.
Oh, for the off-the-bencher hereinabove recited by Judge AIM Marshall, see my blogpost “Rounders’ Day, Again,” 4/22/24.*
- https://taishofflaw.com/2024/04/22/rounders-day-again/ recites aboive
Taishoff Law 
The rarest is the unassisted triple play, but I think Mr. Swanson (what does he teach those McDuffie County kids, anyway?) qualified for that a few petitions ago.
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Mr. Kamman, agreed as to fielders (Bill Wambsganss’ in the 1920 World Series is absolutely unique) and as to pitchers (Don Larsen’s perfect game in the 1956 World Series), but among batters hitting for the cycle is truly rare. That said, I stand by my award to Brian Dean Swanson.
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