Bruce M. Crow - Page 11

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               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).  As previously indicated,                      
          petitioner's position, as articulated in his amended petition and           
          second amended petition, consists solely of tax protester                   
          rhetoric and legalistic gibberish.  Based on well-established               
          law, petitioner's position is frivolous and groundless.                     
          We are also satisfied that petitioner brought these                         
          proceedings primarily for purposes of delay.  Despite the request           
          made in petitioner's Opposition to Summary Judgment filed June 2,           
          1995, that he be given a further opportunity to file a proper               
          amended petition, petitioner filed a second amended petition, and           
          later a motion for reconsideration, filled with time-worn tax               
          protester arguments.  Under the circumstances, it is evident that           
          petitioner regards this case as a vehicle to protest the tax laws           
          of this country and nothing more.  It is equally clear that                 
          petitioner filed his Opposition to Summary Judgment with the                
          willful intent to mislead the Court and protract these                      
          proceedings.  Having to deal with this matter wasted the Court's            
          time, as well as respondent's.  Moreover, taxpayers with genuine            
          controversies were delayed.                                                 
          Petitioner was warned that the Court would consider imposing                
          a penalty under section 6673(a)(1) in the event of his failure to           

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