Richard John Florance, Jr. - Page 12

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               We find that petitioner had no income tax withheld and paid            
          no estimated income taxes for 1997 and that no exception pursuant           
          to section 6654(e) applies.  We hold that petitioner is liable              
          for the addition to tax pursuant to section 6654(a).                        
                    4.   Section 6673                                                 
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay to the United States a penalty not to exceed                
          $25,000 if the taxpayer took frivolous or groundless positions in           
          the proceedings or instituted the proceedings primarily for                 
          delay.  A position maintained by the taxpayer is “frivolous”                
          where it is “contrary to established law and unsupported by a               
          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 filed numerous frivolous documents and motions              
          with the Court.  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 will not painstakingly address petitioner’s assertions           
          “with somber reasoning and copious citation of precedent; to do             






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