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the notice of deficiency. See Coleman v. Commissioner, 791 F.2d
68, 71 (7th Cir. 1986). Rather, the record demonstrates that
petitioner regards this case as a vehicle to espouse his own
misguided views. Petitioner’s position, as set forth in his
petition and as enunciated at trial, consists solely of frivolous
and meritless claims.
We are also convinced that petitioner instituted and
maintained this proceeding primarily, if not exclusively, for
purposes of delay. Having to deal with this matter wasted the
Court’s time, as well as respondent’s. Moreover, taxpayers with
genuine controversies may have been delayed.
Petitioner has previously been told by this Court, as well
as by two Courts of Appeals, that his contentions are completely
without merit or frivolous. He has also twice been sanctioned by
this Court pursuant to section 6673 in the amount of $5,000.
Accordingly, we exercise our discretion under section
6673(a)(1) and require petitioner to pay a penalty to the United
States in the amount of $5,000.
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