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collection, and presented frivolous arguments. We held in both
cases that there was no abuse of discretion, and collection was
allowed to proceed. We also imposed a penalty of $5,000 under
section 6673(a)(1) upon the taxpayers in both cases.
Similarly, petitioner did not raise any bona fide issues or
collection alternatives. Rather, petitioner presented a
“hodgepodge of unsupported assertions, irrelevant platitudes, and
legalistic gibberish” similar to those previously rejected by
this Court. Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir.
1984); see Dunham v. Commissioner, supra; Brodman v.
Commissioner, supra; Kish v. Commissioner, T.C. Memo. 1998-16;
Fisher v. Commissioner, T.C. Memo. 1996-277. “We perceive no
need to refute these arguments with somber reasoning and copious
citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner,
supra at 1417. The Court rejects these boilerplate tax-protester
types of arguments as frivolous and without merit. As a result,
we hold that respondent did not abuse his discretion in
determining that collection should proceed.
In the instant case, petitioner was specifically warned on
three occasions of the likelihood of a penalty under section
6673(a)(1) if he continued with these arguments.2 Despite the
2 Sec. 6673(a)(1) provides:
(continued...)
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