Over the years I’ve argued for some form of judicial uniformity in handing out Section 6673 frivolity chops, lest some frivolite claim arbitrary and capricious on appeal or reargument. I am surprised no frivolite has tried this on before now, at least during the fourteen (count ’em fourteen, and I have) years I’ve been running this blog. Now it seems we are getting a more or less uniform approach.

Judge Cary Douglas Pugh doesn’t schedule the previous appearances of Paul H. Christiansen, T. C. Memo. 2025-67, filed 6/26/25, although she does refer to the T. C. Memo. his last USTC venture generated (and which I did not blog, as it was the usual protester/defier jargon and jive).  And Judge Adam B. (“Sport”) Landy did caution Paul (who appeared with spouse Terre) back in March.

Judge Cary Douglas Pugh gave Paul plenty of warning this time.

“In our Order granting the parties’ joint Motion to Submit Case Pursuant to Rule 122, we cautioned petitioner that a section 6673 penalty might be imposed if he advanced arguments that this Court and others have deemed frivolous. This Court also warned him in Christiansen, T.C. Memo. 2025-21, at *8, that ‘a penalty may be imposed in any future case before this Court should [petitioner] continue to pursue [his] misguided positions.’

“Petitioner did not heed our warnings, instead offering similar arguments in his opening and answering briefs. We therefore will impose a penalty of $1,000 pursuant to section 6673(a)(1) on petitioner. We again warn him that if he does not abandon these misguided positions in future filings before this Court, a greater penalty may be imposed.” T. C. Memo. 2025-67, at pp. 4-5. (Footnote omitted).

The omitted footnote says T. C. Memo. 2025-21 was filed two weeks before Paul filed his frivolous opening brief. So Paul can’t claim he wasn’t warned.