William Santangelo - Page 13

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          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 his own 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, supra            
          at 71.  Petitioner's position, as set forth in the petition and             
          the amended petition, as well as in the other documents that                
          petitioner submitted, 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 may have been delayed.                                
               Finally, we are convinced that petitioner is, and was at the           
          time that he filed his petition, well aware of the provisions of            
          section 6673(a), as demonstrated by the references to that                  
          section in the petition and the attachments thereto.                        




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