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legalistic gibberish. Based on well established law,
petitioner's position is frivolous and groundless.
We recognize that petitioner did include in his petition
allegations alternative to his tax protester arguments, namely,
that if his compensation for services rendered "were arguably
determined to be income", then he is entitled to deduct "all
money spent in order to earn money pursuant to IRC Section 162",
as well as "a number of itemized deductions". Such allegations,
however, are clearly secondary to the tax-protester arguments;
moreover, they were never pursued by petitioner. We think that
such allegations were, at best, a mere decoy, designed to avoid a
pretrial motion to dismiss for failure to state a claim under
Rule 40.
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 were delayed. See Voss v. Commissioner,
T.C. Memo. 1989-238 (taxpayers instituted proceedings in this
Court primarily for delay where they "exhibited total disinterest
in presenting or proving the merits, if any, of their cases.").
Finally, we note that respondent provided petitioner, well
in advance of trial, with copies of two recent cases of this
Court in which we discussed the provisions of section 6673 and
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