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Sunday, March 02, 2003


Tommy Ray Smith is a nut-case tax protester challenging liability for taxes at hearing on collection. Tax Court allowed the collection and imposed a $500 fine.

As if in response to my last post regarding the disrespectful, dismissive, and paranoid-enabling tactic of just stating (correctly) that petitioners' arguments are frivolous, but not explaining why, Tax Court here, in a footnote, quoted a portion of Mr. Smith's petition that accuses the Tax Court of repeatedly ignoring the law by labeling arguments as �frivolous� without citing authority. While I understand Tax Court�s exasperation with dealing with these people (I feel my time reviewing Tax Court Opinions is wasted by reading these cases), this is Tax Court�s job. State court judges have to give detailed, well-reasoned opinions with proper authority before they send murders off to the death chamber, and these time-wasters deserve the same courtesy before Tax Court penalizes them. If the extra time it takes for Tax Court to cut-and-paste these explanations into these cases over and over again requires that the penalties be raised to compensate for the time involved, so be it. It is these nut-cases fault, and they should have to pay.

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