Frivolous Taxpayers and the Jurists who Loathe Them
Frivolous taxpayers are amongst my absolute favorites. The opinions that they spawn are just wonderful breaks in an otherwise monotonous string of upheld determinations…especially when they involve crazy German nationals, as no less than three did in 2020. In this article, we examine the frivolous return penalty (IRC § 6702) and the frivolous petition penalty (IRC § 6673(a)(1)). In doing so, we include a discussion of some of the taxpayers that made 2020 so much