Michael and Michelle Rough - Page 8

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               Petitioner was not to be deterred.  As noted supra,                    
          petitioner attempted to use respondent's witness, Mr. Langeliers,           
          as a foil to again subject the Court to Myrland's sottish opus              
          (Exhibit 3 for identification).  He was not permitted to do so.             
               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 amply demonstrates that petitioners            
          were not interested in disputing the merits of the deficiency in            
          income tax as set forth in the notice of deficiency.  Rather, the           
          record clearly demonstrates that petitioners attempted to use               
          this Court as a forum to protest the tax laws of this country and           
          to impose upon this Court their misguided tax protester views.              
               Petitioners' position, demonstrated at trial, consists                 
          solely of their reliance on tax protester rhetoric and legalistic           
          gibberish.  We are also convinced that petitioners 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.  Petitioner's conduct in this           
          case was patently egregious.                                                






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