- 9 -
(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 so might
suggest that these arguments have some colorable merit.” Crain
v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
We conclude petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. Accordingly, pursuant to
section 6673(a) we hold petitioner is liable for a $12,500
penalty.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011