Kenneth E. Bixler - Page 13

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               We turn next to respondent's Motion To Impose Sanctions For            
          Petitioner's Failure To Comply With Order Directing Production Of           
          Documents.  In view of the action that we will take in respect of           
          respondent's motion to dismiss, this motion will be denied as               
          moot.                                                                       
               We now consider respondent's Motion To Impose Sanctions                
          Pursuant To I.R.C. section 6673.                                            
               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 deficiency in              
          income tax or the penalties 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, 791              
          F.2d 68, 71 (7th Cir. 1986).  Petitioner's position, as set forth           
          in the petition, consists of tax protester rhetoric and                     






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