- 33 -                                                  
                        (B) the taxpayer’s position in such                                            
                        proceeding is frivolous or groundless, or                                      
                        (C) the taxpayer unreasonably failed to                                        
                        pursue available administrative remedies,                                      
                  the Tax Court, in its decision, may require the                                      
                  taxpayer to pay to the United States a penalty not in                                
                  excess of $25,000.                                                                   
                        3.  Discussion                                                                 
                  A taxpayer’s position is frivolous “if it is contrary to                             
            established law and unsupported by a reasoned, colorable argument                          
            for change in the law.  * * *  The inquiry is objective.  If a                             
            person should have known that his position is groundless, a court                          
            may and should impose sanctions.”  Coleman v. Commissioner, 791                            
            F.2d 68, 71 (7th Cir. 1986); see also Hansen v. Commissioner, 820                          
            F.2d 1464, 1470 (9th Cir. 1987) (trial court’s finding that                                
            taxpayer should have known that claim was frivolous allows for                             
            section 6673 penalty); Booker v. Commissioner, T.C. Memo.                                  
            1996-261.                                                                                  
                  We have already concluded that the petitions make nothing                            
            but frivolous arguments.  See supra sec. I.B.  Hae-Rong Ni is                              
            both petitioner in his own right and, as trustee, petitioner for                           
            the trusts.  He was not represented by counsel when he filed the                           
            petitions in these cases.  Attached to respondent’s memorandum is                          
            a copy of a diploma issued by Oregon State University in 1984,                             
            conferring on one Hae-Rong Ni the degree of Doctor of Philosophy.                          
            In respondent’s memorandum, he states that Hae-Rong Ni is highly                           
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