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conduct to settled tax principles. Coleman v. Commissioner,
supra; see also Takaba v. Commissioner, 119 T.C. 285, 295 (2002);
Grasselli v. Commissioner, T.C. Memo. 1994-581. Section 6673 is
a penalty provision intended to deter and penalize frivolous
claims and positions in proceedings before this Court. Bagby v.
Commissioner, 102 T.C. 596, 613-614 (1994).
In this proceeding now before the Court, petitioner asserts
nothing but frivolous and groundless arguments. We believe that
petitioner will continue to do so unless and until he is sent a
message that his behavior is unacceptable. Petitioner raised the
same arguments in Lange involving his purported return for 2000.
We advised petitioner then that his arguments were frivolous and
that he risked a section 6673 penalty if he proceeded. We also
advised petitioner on three occasions in the current proceeding
(at calendar call, at trial, and in a subsequent order) that he
risked incurring a section 6673 penalty if he persisted in
advancing frivolous arguments. Following one warning that he was
wasting the Court’s time with his frivolous arguments, petitioner
replied: “I understand what you are saying” but “I don’t
consider it a waste.” It is apparent from the entire record that
petitioner instituted or maintained this proceeding primarily, if
not exclusively, as a protest against the Federal income tax
system and his proceeding in this Court is merely a continuation
of petitioner’s refusal to acknowledge and satisfy his tax
obligations. We therefore shall require petitioner to pay a
penalty of $5,000 pursuant to section 6673(a)(1). In addition,
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