Frivolous Income Tax Return

ID:
UILC:
CCA_2014121716185644
6702.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201502013
Release Date: 1/9/2015
From:
Sent: Wednesday, December 17, 2014 4:18:57 PM
To:
Cc:
Bcc:
Subject: Section 6702(a) penalty
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As discussed, the following cases support the application of the section 6702(a) penalty in a case in which there are multiple requests for refund for the same tax year containing frivolous arguments:
 Callahan v. CIR, 130 T.C. 44, 53 (2008) (documents requesting refunds are purported returns)
 Kelly v. United States, 789 F.2d 94 (1st Cir. 1986) (taxpayer cannot disclaim that correspondence is not a purported return when the taxpayer has included sufficient documentation to request a refund). See also Olson v. United States, 760 F.2d 1003 (9th Cir. 1985); Lovell v. United States, 755 F.2d 517 (7th Cir. 1984).
Please let us know if you need any additional information.
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