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Shortly before trial, petitioner attempted to withdraw his
petition, again asserting a variety of frivolous arguments.
Notwithstanding repeated warnings, petitioner persisted in
ignoring the facts and law applicable to his case. His conduct
was patently willful. Because he was on notice of the lack of
merit to his claims, his positions were taken in bad faith. We
conclude that petitioner's conduct in this case justifies a
penalty under section 6673 in the amount of $15,000. See Granado
v. Commissioner, 792 F.2d 91 (7th Cir. 1986), affg. T.C. Memo.
1985-237; Sloan v. Commissioner, 102 T.C. 137, 148-149 (1994),
affd. 53 F.3d 799 (7th Cir. 1995); Singer v. Commissioner, T.C.
Memo. 1990-222, affd. without published opinion 935 F.2d 1282 (3d
Cir. 1991).
Both of respondent's motions will be granted.
An appropriate order and
decision will be entered.
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