Forest L. Buckmaster - Page 16

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               We agree with respondent that petitioner is liable for a               
          penalty under section 6673(a)(1), and we require him to pay a               
          penalty to the United States in the amount of $5,000.                       
          Petitioner's conduct throughout this proceeding has convinced us            
          that he instituted and maintained this proceeding primarily for             
          delay.  His position in this proceeding also is groundless and              
          frivolous.  See Coleman v. Commissioner, 791 F.2d 68, 71 (7th               
          Cir. 1986); see also Neitzke v. Williams, 490 U.S. 319 (1989)               
          (defining legal frivolousness).  Petitioner's insistence on                 
          pursuing his fruitless arguments has consumed time and effort of            
          this Court (and of respondent) that could have otherwise been               
          devoted to resolving bona fide claims of other taxpayers.  See              
          Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986).                             
               We have considered all arguments made by petitioner in this            
          proceeding and, to the extent not discussed above, find them to             
          be irrelevant or without merit.  To reflect the foregoing,                  
                                                  An appropriate order and            
                                             decision will be entered for             
                                             respondent except for the                
                                             addition to tax under section            

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