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law * * * The inquiry is objective. If a person should have
known that his position is groundless, a court may and should
impose sanctions." Coleman v. Commissioner, 791 F.2d 68, 71 (7th
Cir. 1986); Booker v. Commissioner, T.C. Memo. 1996-261; see also
Hansen v. Commissioner, 820 F.2d 1464, 1470 (9th Cir. 1987)
(apparent finding that petitioner should have known that claim
was frivolous allows for section 6673 penalty).
Based on the record in this case, we conclude that
petitioner's position in this proceeding is both frivolous and
groundless and that petitioner undertook certain actions
primarily for delay. Petitioner has never substantively
addressed the pertinent issues in this case, which relate to the
correct determination of income and deductions for the years in
issue and various additions to tax. Instead, petitioner has
asserted absurd, discredited, and misguided tax-protester
arguments such as the following: (1) the Internal Revenue Code
does not make anyone "liable" for an income tax, (2) the Internal
Revenue Code contains no mandatory provisions, and therefore,
compliance is voluntary, (3) the Tax Court has no authority to
decide matters of law or Constitutional issues, and (4) an income
tax on petitioner’s rents pursuant to Pollock v. Farmers’ Loan &
Trust Co., supra, is an unapportioned direct tax.
Petitioner has maintained her frivolous and groundless
positions not only by way of her testimony and on brief, but also
in numerous additional written submissions to the Court, all of
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