Gary Anders - Page 8




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          where 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); see also Horn v.             
          Commissioner, 90 T.C. 908, 946 (1988).                                      
               The record in this case convinces us that petitioner was not           
          interested in disputing the merits of either the deficiencies in            
          income tax or the additions to tax determined by respondent.                
               We are also convinced that petitioner instituted and                   
          maintained this proceeding primarily, if not exclusively, for               
          purposes of delay.  Petitioner's outrageous tactics of delay,               
          including his egregious abuse of the bankruptcy process, resulted           
          in the waste of limited judicial and administrative resources.              
          Moreover, taxpayers with genuine controversies were delayed.                
               Furthermore, petitioner's position, based on stale and                 
          meritless contentions, is manifestly frivolous and groundless.              
          Claiming status as a nonresident alien in order to avoid Federal            
          income tax is a hackneyed argument that has been universally                
          rejected by this and other courts.  See, e.g., Kerr v.                      
          Commissioner, T.C. Memo. 1994-582, affd. without published                  
          opinion 73 F.3d 369 (9th Cir. 1995); see also Haskins v.                    
          Commissioner, T.C. Memo. 1999-106; Harkless v. Commissioner, T.C.           
          Memo. 1999-58; McQuatters v. Commissioner, T.C. Memo. 1998-88;              
          Peterson v. Commissioner, T.C. Memo. 1997-463; Heun v.                      
          Commissioner, T.C. Memo. 1997-265; Mancebo v. Commissioner, T.C.            





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