MatrixInfoSys Trust - Page 10




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          142(a).  Accordingly, we sustain respondent’s determination                 
          regarding this matter.                                                      
               Respondent also determined that petitioner is liable for               
          additions to tax under section 6654 for failure to make estimated           
          tax payments.  Petitioner did not offer any evidence relating to            
          this issue.  See Rule 142(a).  We therefore sustain respondent’s            
          determination as to the additions to tax under section 6654.                
               Finally, we reconsider whether petitioner has engaged in               
          behavior that warrants the imposition of a penalty pursuant to              
          section 6673.  Section 6673(a) authorizes this Court to penalize            
          a taxpayer who (1) institutes or maintains a proceeding primarily           
          for delay, (2) pursues a position in this Court which is                    
          frivolous or groundless, or (3) unreasonably fails to pursue                
          available administrative remedies.  Petitioner’s conduct                    
          throughout this proceeding has convinced us that he instituted              
          and maintained this proceeding primarily for delay and pursued a            
          position that was frivolous and groundless.                                 
               From the filing of his petition to the submission of his               
          brief, petitioner has devoted much of his time to shopworn                  
          arguments characteristic of the tax-protester rhetoric that has             
          been universally rejected by this and other courts.  We refuse to           
          painstakingly address petitioner’s assertions “with somber                  
          reasoning and copious citation of precedent” because “to do so              
          might suggest that these arguments have some colorable merit.”              






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