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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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