Taxpayer, a self-employed hearing aid specialist, claimed he had no taxable income and made no estimated tax payments on his 2006 and 2007 tax returns. Through third-party information returns and a bank account analysis, the IRS determined he had unreported business receipts of $209,331 for 2006 and $279,600 for 2007. The IRS found his tax returns to be invalid and prepared substitute returns with notices of deficiency. The taxpayer argued he was not subject to tax because he was not involved in a trade or business. Finding him liable for the deficiencies, the Tax Court’s Judge Marvel said, “without exception, petitioner has raised only frivolous and groundless arguments.” In addition to the tax deficiency, penalties of $30,000 were assessed for wasting the time and resources of the Court. John Lewis Hill , TC Memo 2013-264 (Tax Ct.)