I rely on my readers to keep my reportage accurate; where I stray, I invite my readers to use the “comment” function that WordPress obligingly inserts at the foot of each of my blogposts. I read them all. Just skip down below the advertisements.

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All that said, I count three (count ’em, three) separate warnings from ex-Ch J Maurice B. (“Mighty Mo”) Foley to Theya Kanagaratnam, Docket No. 15922-23, filed 3/27/25 (that date marks my Year 58 in the NYS Bar; still crazy after all these years). The warnings involved Theya’s “wages-aren’t-taxable-income” frivolities, asserted at motion and trial stages.

“Petitioner raises several frivolous contentions that, in essence, challenge the taxability of her wages. The Court admonished petitioner several times. Despite these warnings, petitioner continued to file documents that presented frivolous contentions. Petitioner does not contest receiving the unreported wages paid to her from her employer. Petitioner’s contentions on whether those wages are taxable are “contrary to established law and unsupported by a reasoned, colorable argument for change in the law.” See Wnuck, 136 T.C. at 513 n.14 (quoting Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir.1986)). Accordingly, petitioner is liable for a section 6673(a) penalty.” Order, at p. 3.

So ex-Ch J Mighty Mo lays a $5K Section 6673 chop on Theya. By my arithmetic, that works out to $1666.67 per ignored frivolity warning.

For latecomers, the Scott Wnuck story can be found in my blogpost “One’ll Get You Five,” 5/31/11.