-11-
otherwise make any legitimate attempt to prove respondent’s
determinations wrong. Petitioner was warned by respondent before
trial, and he was warned by the Court during trial, that his
position (or lack thereof) was without merit and could subject
him to a penalty of up to $25,000 under section 6673(a).
Notwithstanding the fact that we previously sanctioned petitioner
in Hill v. Commissioner, T.C. Memo. 2002-272, for $3,500,
petitioner continues to pursue his frivolous and/or groundless
arguments. Petitioner has disregarded these warnings and has
consumed wastefully the time, resources, and effort of the Court.
We conclude from the record that petitioner’s positions in this
proceeding are frivolous and without merit. We also conclude
from the record that petitioner has instituted and maintained
this proceeding primarily for delay. Pursuant to section
6673(a), we require petitioner to pay to the United States a
penalty of $15,000.1
1 We note that petitioner has two more cases before the
Court (docket Nos. 8690-02 and 14771-02).
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