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reasoned, colorable argument for change in the law.” Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986); see also Hansen v.
Commissioner, 820 F.2d 1464, 1470 (9th Cir. 1987) (section 6673
penalty upheld because taxpayer should have known claim was
frivolous).
Petitioner has advanced shopworn arguments characteristic of
tax-protester rhetoric that has been universally rejected by this
and other courts. Wilcox v. Commissioner, 848 F.2d 1007 (9th
Cir. 1988), affg. T.C. Memo. 1987-225; Carter v. Commissioner,
784 F.2d 1006, 1009 (9th Cir. 1986). We shall not painstakingly
address petitioner’s assertions “with somber reasoning and
copious citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984).
We conclude that petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. We take this opportunity to
warn petitioner that the Court will impose a penalty pursuant to
section 6673 if he returns to the Court and proceeds in a similar
fashion in the future.
To reflect the foregoing,
Decision will be entered
for respondent.
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