Steven Matthew Langley - Page 8

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            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 tax 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 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 and in the motion to dismiss for lack of                                      
            jurisdiction, consists solely of stale and time-worn tax                                      
            protester rhetoric.  Based on well established law, petitioner's                              
            position is frivolous and groundless.                                                         
                  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.                                                           
                  In view of the foregoing, we will exercise our discretion                               
            under section 6673(a)(1) and require petitioner to pay a penalty                              




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