Tags
Sanctions
Practice
Foreclosed
How Courts Respond: The Sanction Regime and the Doctrine of Non-Engagement
When litigants raise alternate tax theories, federal courts don't just rule against them — they refuse to reason about them. This essay examines the Crain doctrine, §6673 penalties, and what 'frivolous' actually means in practice.
The Truth About Frivolous Tax Arguments
The government's own catalog of rejected theories. Useful as a counter-reference for what the establishment treats as foreclosed.
Frivolous Position
A category of tax-related argument that triggers automatic sanctions under §6702 and §6673. The doctrinal mechanism by which the courts foreclose engagement with alternate-tax theories.