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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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