- 8 -
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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