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judgment with the willful intent to protract these proceedings
and that petitioner regards these cases as a means to protest the
tax laws of this country and nothing more. Having to deal with
this matter wasted the Court's time, as well as respondent's.
Petitioner is no stranger to this Court and is aware that
section 6673(a)(1) is available to be used against him. In fact,
the Court imposed a penalty upon petitioner pursuant to section
6673(a)(1) in Fox v. Commissioner, T.C. Memo. 1993-277, affd.
without published opinion 69 F.3d 543 (9th Cir. 1995), and in Fox
v. Commissioner, T.C. Memo. 1989-232. Regrettably, petitioner
has failed to grasp that his tactics will not be tolerated in
this Court. Considering all of the circumstances, we will
exercise our discretion under section 6673(a)(1) and require
petitioner to pay a penalty to the United States in the amount of
$5,000 in each of the two dockets herein. Coleman v.
Commissioner, supra at 71-72; Crain v. Commissioner, 737 F.2d at
1417-1418; Abrams v. Commissioner, 82 T.C. 403, 408-411 (1984).7
7 See also Granado v. Commissioner, T.C. Memo. 1985-237,
affd. 792 F.2d 91, 94 (7th Cir. 1986), where the Court of Appeals
held that the raising of one nonfrivolous argument among many
frivolous arguments was not enough to negate the imposition of
the penalty.
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