On June 29, 2021, the Tax Court issued a Memorandum Opinion in the case of Muhammad v. Commissioner (T.C. Memo. 2021-77). The primary issue presented in Muhammad v. Commissioner was whether the petitioner’s arguments were completely frivolous, or just a little frivolous, so as to support the frivolous argument penalty under IRC § 6673(a)(1)(B). Held: Petitioner was completely full of shit; penalties ensued. Overview of Muhammad v. Commissioner The question presented in this case is