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immaterial in this case. Moreover, petitioner had been placed on
notice, by the holding in his previous case, that such evidence
and the arguments in connection therewith possessed no merit.
The voluminous documents petitioner presented to this Court
had no relevance to his case. When that is coupled with his
nonsensical arguments, the Court is provoked to apply the penalty
under section 6673(a)(1). The fact that petitioner believed, or
may have believed, that he was entitled to a larger home interest
deduction for 1991 than the amount allowed by respondent is of no
consequence in this matter. In Sloan v. Commissioner, 102 T.C.
137, 148 (1994), affd. 53 F.3d 799 (7th Cir. 1995), this Court
observed that "The mere fact that not every one of petitioner's
arguments is frivolous or groundless does not eliminate the
applicability of section 6673." See also Granado v.
Commissioner, 792 F.2d 91, 94 (7th Cir. 1986), affg. T.C. Memo.
1985-237. Petitioner's possible belief with regard to his home
interest deduction does not shield him from the imposition of the
penalty under section 6673(a)(1). By far, the majority of
petitioner's pleadings and arguments are frivolous and
demonstrate that petitioner regarded this case as a vehicle to
protest the tax laws of this country and espouse his own
misguided views. This Court does not look with favor upon such
tactics.
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