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a penalty under section 6673(a)(1), and we require her to pay a
penalty to the United States in the amount of $2,500. Petitioner's
conduct throughout this proceeding has convinced us that she
instituted and maintained this proceeding primarily for delay.
Moreover, her position in this proceeding 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 her
fruitless argument 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. We perceive no need to refute petitioner's protester
arguments with somber reasoning; to do so might suggest they have
colorable merit. Crain v. Commissioner, 737 F.2d 1417 (5th Cir.
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