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Johnson v. Commissioner of Internal Revenue

District court was required to find bad faith before imposing attorney sanctions under IRC ' 6673(a)(2); attorney's bad faith in responding to IRS discovery requests supported sanction award requiring payment of IRS attorney fees.

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The full case caption appears at the end of this opinion.

Posner, Circuit Judge. Attorney Joe Alfred Izen, Jr., has appeared in the United States Tax Court in many cases since the early 1980s. A number of them, including the recently decided Muhich v. Commissioner, 238 F.3d 860 (7th Cir. 2001), involve the same script: the IRS determines a deficiency arising from the use of sham trusts established for the taxpayer by a promoter; the taxpayer petitions for redetermination of the deficiency; Izen appears for the taxpayer; the case drags on, with the taxpayer sometimes resisting discovery; the court usually finds the taxpayer’s arguments frivolous and either threatens or imposes sanctions. Oelze v. Commissioner, 723 F.2d 1162 (5th Cir. 1983) (per curiam); Watson v. Commissioner, 690 F.2d 429 (5th Cir. 1982) (per curiam); Muhich v. Commissioner, 77 T.C.M (CCH) 2143 (1999), aff’d, 238 F.3d 860 (7th Cir. 2001); Ripley v. Commissioner, 53 T.C.M. (CCH) 262 (1987); Dixon v. Commissioner, 79 T.C.M. (CCH) 1803, 1810 (2000).

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