Penalties Under the Code
Crazy Germans

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

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Scott St. Amand April 15, 2021
Failure to Communicate with IRS

Lloyd v. Commissioner
T.C. Memo. 2020-92

On June 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Lloyd v. Commissioner (T.C. Memo. 2020-92). The issue before the court in Lloyd v. Commissioner was whether a taxpayer’s claims that “the income tax law is null and void” and that “he is entitled to a religious exemption from paying income tax because he is functioning as a church relieves him from the requirement to file and/or pay Federal income

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Scott St. Amand June 22, 2020
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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)

Read More »
Scott St. Amand April 15, 2021

Lloyd v. Commissioner
T.C. Memo. 2020-92

On June 22, 2020, the Tax Court issued a Memorandum Opinion in the case of Lloyd v. Commissioner (T.C. Memo. 2020-92). The issue before the court in Lloyd v. Commissioner was whether a taxpayer’s claims that “the income tax law is null and void” and that “he is entitled to

Read More »
Scott St. Amand June 22, 2020