- 13 - 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 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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