- 15 -
established. Cf. Pierson v. Commissioner, 115 T.C. 576, 581
(2000). Petitioner filed frivolous documents and motions with
the Court. Petitioner’s position, based on stale and meritless
contentions, is manifestly frivolous and groundless, and he has
wasted the time and resources of the Court. We are convinced
that petitioner instituted and maintained these proceedings
primarily for delay. Accordingly, we shall impose a penalty of
$10,000 pursuant to section 6673.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011