- 10 - 142(a). Accordingly, we sustain respondent’s determination regarding this matter. Respondent also determined that petitioner is liable for additions to tax under section 6654 for failure to make estimated tax payments. Petitioner did not offer any evidence relating to this issue. See Rule 142(a). We therefore sustain respondent’s determination as to the additions to tax under section 6654. Finally, we reconsider whether petitioner has engaged in behavior that warrants the imposition of a penalty pursuant to section 6673. Section 6673(a) authorizes this Court to penalize a taxpayer who (1) institutes or maintains a proceeding primarily for delay, (2) pursues a position in this Court which is frivolous or groundless, or (3) unreasonably fails to pursue available administrative remedies. Petitioner’s conduct throughout this proceeding has convinced us that he instituted and maintained this proceeding primarily for delay and pursued a position that was frivolous and groundless. From the filing of his petition to the submission of his brief, petitioner has devoted much of his time to shopworn arguments characteristic of the tax-protester rhetoric that has been universally rejected by this and other courts. We refuse to painstakingly address petitioner’s assertions “with somber reasoning and copious citation of precedent” because “to do so might suggest that these arguments have some colorable merit.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011