Rob R. Olsen - Page 8

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                  As relevant herein, section 6673(a)(1) authorizes the Tax Court to                  
            require a taxpayer to pay to the United States a penalty not in excess of                 
            $25,000 whenever it appears that proceedings have been instituted or                      
            maintained by the taxpayer primarily for delay or that the taxpayer's position            
            in such proceeding is frivolous or groundless.                                            
                  The record in this case convinces us that petitioner was not interested             
            in disputing the merits of either the deficiencies in income taxes or the                 
            additions to tax determined by respondent in the notice of deficiency.                    
            Rather, the record demonstrates that petitioner regards this case as a vehicle            
            to protest the tax laws of this country and espouse 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, as set forth in the petition and the 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 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, taxpayers with genuine controversies were delayed.                              
                  In view of the foregoing, we will exercise our discretion under section             
            6673(a)(1) and require petitioner to pay a penalty to the United States in the            
            amount of $2,000.  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, supra at 408-411.                                     

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