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section 6673 penalty on taxpayers who have made such arguments.
Indeed, the Court so advised petitioner in its October 14, 1994,
order.
In his trial memorandum, however, petitioner continued to
assert the same groundless claims. Petitioner stated, for
example, that "the free exercise and enjoyment of the God-given
and constitutionally secured right to lawfully acquire property
or compensatory income, by lawfully contracting one's own labor
in innocent and harmless activities, for lawful compensation,
cannot be (and therefore has not been) taxed for revenue
purposes." Petitioner made similar assertions in his request for
admissions, in his proposed joint stipulation of facts, and in a
list of 21 "Special Questions for the Tax Court" that served no
function but to restate petitioner's antitax views.
At the beginning of the trial, the Court warned petitioner
that it would impose a penalty, up to $25,000, if it found
his position to be frivolous and groundless. During the trial,
the Court admonished petitioner several times to set forth a
legitimate argument for not paying the taxes due. Ignoring these
admonitions, petitioner consumed all of his trial time asserting
that his income is not subject to taxation, contending that this
Court did not have jurisdiction, and asking extraneous questions.
Among his inquiries, he asked: "Am I here under common law?",
"Is this a Court of Admiralty?", and "Does this Court have
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