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and other courts. Wilcox v. Commissioner, 848 F.2d 1007 (9th
Cir. 1988), affg. T.C. Memo. 1987-225; Carter v. Commissioner,
784 F.2d 1006, 1009 (9th Cir. 1986). We shall not painstakingly
address petitioner’s assertions “with somber reasoning and
copious citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984).
We conclude that in both dockets petitioner’s position was
frivolous and groundless and that petitioner instituted and
maintained these proceedings primarily for delay. Although there
were some minor differences between the frivolous and dilatory
actions taken in each docket prior to consolidation, petitioner’s
actions in both dockets merit similar penalties. Accordingly,
pursuant to section 6673(a), we hold petitioner is liable for a
$12,500 penalty in docket No. 20928-03 and a $12,500 penalty in
docket No. 15561-04.
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