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the notice of deficiency. See Rule 142(a). Accordingly,
we hereby sustain the deficiencies and additions set
forth in the notice of deficiency. We need not consider
respondent's motion for judgment on the pleadings, and we
will deny respondent's motion as moot.
In view of the fact that petitioner disregarded the
Court's warning and persisted in presenting at trial the
tax protester arguments advanced in his trial memorandum
that have been rejected by the courts in the past, we
find that petitioner instituted or maintained this case
primarily for delay, and we find that petitioner's position
in this case is frivolous. Accordingly, we will require
petitioner to pay to the United States a penalty in the
amount of $10,000, pursuant to section 6673(a).
To reflect the foregoing,
An appropriate order
and decision will be entered.
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Last modified: May 25, 2011