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The first issue for decision is whether petitioner has
proved any error in respondent's determinations in the statutory
notice of deficiency. Based on the record, we find that
petitioner has failed to prove any error in respondent's
determinations. See Rule 142(a). We will not address
petitioner's tax protester ramblings which were asserted in the
attachments to his petition, in attachments to his trial
memorandum, and at trial. As was stated by the Court of Appeals
for the Fifth Circuit: "We perceive no need to refute these
arguments with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit." Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984). We hold that respondent's determinations of
deficiencies in petitioner's Federal income taxes for 1991 and
1993 and additions to tax pursuant to sections 6651(a)(1) and
6654(a) for 1991 and 1993 are sustained.
The second issue for decision is whether we should, sua
sponte, impose a penalty on petitioner pursuant to section
6673(a). Whenever it appears to this Court that proceedings
before it have been instituted or maintained by the taxpayer
primarily for delay or that the taxpayer's position in such
proceeding is frivolous or groundless, the Court, in its
discretion, may require the taxpayer to pay to the United States
a penalty not in excess of $25,000. See sec. 6673(a)(1)(A) and
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Last modified: May 25, 2011