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ultimate payment of taxes. He failed to comply with our standing
pretrial order and played semantical games throughout this
proceeding. We find that his second amended petition filed
September 29, 1997, was merely another delaying tactic used to
prolong this proceeding. Petitioner knew that on May 18, 1995,
the United States Court of Appeals for the Ninth Circuit had
affirmed an unpublished order of this Court dated August 24,
1994, which granted respondent's Motion for Judgment on the
Pleadings, dismissing petitioner's case for the years 1991 and
1992.2 He has once again caused this Court to waste its limited
resources reviewing his rejected taxpayer protests which he knew
or should have known are without merit.
In view of the foregoing, we will exercise our discretion
under section 6673(a) and require petitioner to pay a penalty to
the United States in the amount of $3,000.
To reflect the foregoing,
An appropriate order will
be issued and a decision will
be entered under Rule 155.
2 Porter v. Commissioner, 56 F.3d 73 (9th Cir. 1995),
affg. without opinion an order of this Court dated Aug. 24, 1994
(granting the Commissioner's motion for judgment on the
pleadings).
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