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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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