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the disclaimers attached to his initial 1996 and 1997 Forms 1040,
the payment of income taxes is voluntary. E.g., Woods v.
Commissioner, 91 T.C. 88, 90 (1988). Whatever legitimate
arguments may underlie his assignments of error, Dr. Trowbridge
has emphasized frivolous arguments and, for that reason alone,
deserves to have a section 6673(a)(1) penalty imposed against
him.
We are also convinced by Dr. Trowbridge’s conduct that he
both instituted and maintained these proceedings for delay, which
is a separate basis for imposing a section 6673(a)(1) penalty.
We struck substantial portions of the petition. His discovery
requests ran to hundreds of pages, and we granted respondent’s
motion for a protective order with respect thereto.
Notwithstanding his active, indeed forceful, prosecution of this
case initially, Dr. Trowbridge abruptly changed course 2 weeks
before trial. At that point, he attempted to withdraw the
petition, asserting a jurisdictional challenge premised on his
disavowal of any commercial relationship with, and any enjoyment
of benefits from, the United States. He refused to appear for
trial, despite notice thereof. We interpret Dr. Trowbridge’s
actions in prosecuting (and not prosecuting) this case as
evidence of his intent to delay these proceedings.
There is a contemporaneous case in this Court involving Dr.
Trowbridge and his 1991-95 taxable years which involves conduct
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