John J. Delgado - Page 10

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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                 
               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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