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Thursday, February 27, 2003


William G. Koenig is a nut-case tax protester challenging liability for taxes at hearing on collection. Tax Court allowed the collection and imposed a $2,000 fine.

This is the best protester opinion from the Tax Court this year. Rather then simply state that they don�t have to explain their reasons, Tax Court methodically established why tax liability was not reviewable, why the collection was legal, and why the penalty would be imposed. They also provided the policy reason that taxpayers with legitimate disputes were being delayed by the protester. They even went so far as to explain in footnotes why the protester�s arguments regarding the underlying liability for income taxes are frivolous.

If only they had explained why they picked $2,000 out of thin air, it would have been a perfect opinion.

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