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primarily for delay, where the taxpayer's position is frivolous
or groundless, or where the taxpayer unreasonably fails to pursue
administrative remedies. A taxpayer's position is frivolous or
groundless 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); Sicalides v.
Commissioner, T.C. Memo. 1989-164.
It is beyond any reasoned dispute that petitioner is subject
to Federal income taxation and that his position in his previous
cases was frivolous, groundless, and instituted primarily for
delay. Fox I, Fox III; see Fox II. Petitioner continues to
waste respondent's and the Court's time with stale tax protester
arguments. Petitioner's written materials show that he has an
ability to twist tax laws to support his frivolous positions.
Fox III. We imposed penalties under section 6673 on our own
motion in Fox I and Fox III, which were filed before petitioner
filed his petition in this case.
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