Ruth R. Johnson-Straub - Page 9

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          remanding T.C. Memo. 1958-85; Swanson v. Commissioner, 65 T.C.              
          1180, 1181-1182 (1976).                                                     
               Because the petition fails to state a claim upon which                 
          relief can be granted, we shall grant respondent's motion to                
          dismiss, as supplemented.  See Scherping v. Commissioner, 747               
          F.2d 478 (8th Cir. 1984).                                                   
               We turn now, on our own motion, to the award of a penalty              
          against petitioner under section 6673(a).                                   
               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 deficiencies in            
          income taxes or the additions to tax determined by respondent in            
          the notices of deficiency.  Rather, the record demonstrates that            
          petitioner regards this case as a vehicle to protest the tax laws           
          of this country and espouse her 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 and the Rule 50 statement, consists solely of               

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