The Tax Court warned a taxpayer that his frivolous argument would not be tolerated, he naturally continued to argue that same point throughout his trial. The stance in question was the taxpayer’s insistence that his independent contractor commissions were loans and so they were not taxable income. But there was no evidence of a repayment plan, nor did he make any “repayments” and he also conveniently forgot to file a return for the year at issue. He persisted in arguing the income was not taxable, and lost, plus the Tax Court handed down a $1,000 frivolous argument penalty.
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