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In order to support his arguments, petitioner has selectively
picked phrases out of context from statutes and rulings. In so
doing, petitioner has chosen to ignore more current or complete
statements of the law. In that same vein, petitioner has chosen
to ignore and/or not follow case precedent and interpretation of
the statutory law.
Under these circumstances we are convinced and hold that
petitioner’s position in this proceeding is frivolous and has
been interposed primarily to protest the tax laws of this country
and/or to delay collection activity by respondent. Accordingly,
we hold that petitioner is liable for a $1,500 penalty under
section 6673(a)(1).
To reflect the foregoing,
An appropriate order and
decision will be entered granting
respondent’s motion for summary
judgment.
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Last modified: May 25, 2011