Hart v. Commissioner
This text of 14 F. App'x 990 (Hart v. Commissioner) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
MEMORANDUM2
Taxpayer Philip Lewis Hart appeals pro se the Tax Court’s decision holding him hable for income tax deficiencies and penalties, and imposing sanctions against him under Internal Revenue Code § 6673 for bringing frivolous proceedings.
The Tax Court properly determined that Hart’s wages and other income are subject to federal income tax, In Re Becraft, 885 F.2d 547, 548 (9th Cir.1989); Grimes v. Commissioner, 806 F.2d 1451, 1453 (9th Cir.1986) (per curiam), and that he was hable for additions to tax and accuracy-related penalties and sanctions pursuant to 26 U.S.C. §§ 72(t), 6651(a)(1), 6654, 6662(a) and 6673.
We grant the Commissioner’s request for sanctions pursuant to Fed. R.App. P. 38 and 28 U.S.C. § 1912 in the amount of $2,000 because the result is obvious and Hart’s appeal is wholly without merit. Olson v. United States, 760 F.2d 1003, 1005 (9th Cir.1985).
AFFIRMED WITH SANCTIONS.
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14 F. App'x 990, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hart-v-commissioner-ca9-2001.