- 10 -- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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