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summary judgment as a matter of law, and we so hold. See, e.g.,
Beard v. Commissioner, supra.
We turn now to an award of a penalty against petitioner
under section 6673(a). The Court may on its own initiative
require a taxpayer to pay such a penalty to the United States
where the circumstances justify its imposition. Horn v.
Commissioner, 90 T.C. 908, 945 (1988).
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 tax or the additions to tax determined by respondent in
the notice of deficiency. Rather, the record demonstrates that
petitioner regards this case as a vehicle to protest the tax laws
of this country and to 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), affg. an unreported order of this
Court. Based on well-established law, petitioner's position is
frivolous and groundless.
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