Mark C. Nagy - Page 7

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            petitioner regards this case as a vehicle to protest the tax laws                          
            of this country and espouse his own misguided views.  A petition                           
            to the Tax Court is frivolous "if it is contrary to established                            
            law and unsupported by a reasoned, colorable argument for change                           
            in the law."  Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir.                           
            1986).  Petitioner's position consists solely of tax protester                             
            rhetoric and legalistic gibberish.  Based on well established                              
            law, petitioner's position is frivolous and groundless.  We are                            
            also convinced that petitioner instituted and maintained this                              
            proceeding primarily, if not exclusively, for purposes of delay.                           
            Having to deal with this matter wasted the Court's time, as well                           
            as respondent's.  Moreover, cases of taxpayers with genuine                                
            controversies were delayed.  In view of the foregoing, we shall                            
            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.  Coleman v. Commissioner, supra at 71-72; Crain v.                                 
            Commissioner, supra at 1417-1418; Coulter v. Commissioner, 82                              
            T.C. 580, 584-586 (1984); Abrams v. Commissioner, 82 T.C. 403,                             
            408-411 (1984).  To reflect the foregoing,                                                 

                                                      An order of dismissal                            
                                                      and decision will be entered.                   









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