-17-
As we have noted, petitioner relies primarily on his stated
beliefs about Federal Reserve Notes; in the course of his
testimony and his filings in the instant case he also adverts to
various constitutional objections. Petitioner does not challenge
the wisdom of the hundred-million-plus people who file tax
returns, but contends that he is not obligated to file tax
returns and will not do so. We do not believe that petitioner
had a good-faith misunderstanding of the Internal Revenue Code or
the Constitution. Petitioner was not bent on presenting a
serious issue to the courts and cooperating with respondent in
doing so. Compare Muste v. Commissioner, 35 T.C. 913, 920-921
(1961), with Habersham-Bey v. Commissioner, 78 T.C. at 313-314.
Petitioner’s asserted confusions are not the sort that enable him
to escape our verdict of fraud. Niedringhaus v. Commissioner, 99
T.C. 202, 216-220 (1992).
We hold for respondent on this issue.
II. Sec. 6673
We turn now, on our own motion, to the award of a penalty
against petitioner under section 6673(a)7.
7 Sec. 6673 provides, in pertinent part, as follows:
SEC. 6673. SANCTIONS AND COSTS AWARDED BY COURTS.
(a) Tax Court Proceedings.--
(1) Procedures instituted primarily for delay,
etc.--Whenever it appears to the Tax Court that--
(continued...)
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