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years in issue. Petitioner offered no evidence or testimony to
refute the stipulated facts. Petitioner has not satisfied her
burden of proof. Respondent is sustained on this issue.
4. Section 6673 Sanctions
At trial respondent moved for sanctions under section 6673
against petitioner on the grounds that she had instituted and
maintained the proceedings primarily for delay and that her
positions were frivolous and groundless. Section 6673(a)(1)
provides that a penalty not in excess of $25,000 may be awarded
"Whenever it appears to the Tax Court that * * * proceedings
before it have been instituted or maintained by the taxpayer
primarily for delay, * * * [or] the taxpayer's position in such
proceeding is frivolous or groundless".
The records in these cases establish that petitioner sought
to delay these proceedings by refusing to stipulate even the most
basic elements of the cases and that she raised only frivolous
factual and legal arguments. Her claims that the notices of
deficiency failed to identify the type of tax involved and that
her source of income was misclassified, for example,
contradicted the record. Petitioner demonstrated that she was
able to research the law, yet she took positions contrary to
established law and unsupported by a reasoned colorable argument.
See Coleman v. Commissioner, supra at 71. Accordingly, we shall
require petitioner to pay a penalty to the United States in the
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