Tags
Section-6673
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.
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.