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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.”
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Last modified: May 25, 2011