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such is the case here, and we believe that a penalty is
appropriate.
Petitioner is a certified public accountant. From his
appearances before us, we know that he is sufficiently conversant
with tax law to understand the issues presented in this case. He
knew of his obligation to present facts concerning his bases in
his securities and the nature of his claimed business expenses.
Nevertheless, for reasons of his own, he has chosen not to do so.
Instead, he has advanced the baseless notion that his receipt of
hundreds of thousands of dollars from liquidation of his account
is not income, but rather a “a partial restitution by
tortfeasor”.
Petitioner’s conduct of this case makes it plain that he has
instituted this action in a renewed attempt to argue that Kidder
Peabody, the University of Chicago, and others, named as
defendants in his previous lawsuits, have wronged him. Two U.S.
District Courts have forbidden petitioner from using their
resources to attack these defendants, and the U.S. Court of
Appeals for the Second Circuit has issued a similar order and
levied sanctions against him. Petitioner has now sought to use
this Court for the same ends, but he may not do so.
Our function is to provide a forum for deciding issues
regarding liability for Federal taxes. Petitioner has interfered
with that function, to the detriment of parties wishing to
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