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contentions. See Crain v. Commissioner, 737 F.2d 1417 (5th Cir. 1984).
Section 6673 authorizes this Court to impose a penalty in
favor of the United States, in an amount not to exceed $25,000,
whenever it appears that the taxpayer's position in a proceeding
is frivolous, groundless, or instituted or maintained primarily
for delay. A petition in 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). In this case,
petitioner made frivolous arguments. She failed to raise any
issue with regard to the correct amount of her income tax
liability, including the additions to tax. Specifically,
petitioner failed to file a petition containing clear and concise
statements of error or statements of fact. Rather, she chose to
assert meritless tax protester-type rhetoric that has been
rejected by numerous courts. Respondent cautioned petitioner, at
least once, regarding her arguments and the possibility of a
penalty being awarded by this Court if she pursued her baseless
claims. Petitioner also refused to follow this Court's Rules of
Practice and Procedure and answer respondent's interrogatories,
and failed to cooperate in this case after invoking our
jurisdiction in response to respondent's determination.
We find that petitioner instituted and maintained this
action primarily for delay and that her position in this
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