Gregory Meeker - Page 9

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          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’s petition, objection, and motion to enforce Rule           
          36 are replete with tax-protester rhetoric, including but not               
          limited to arguments regarding the 16th Amendment.  The same is             
          true for (1) the two documents received at the hearing on                   
          respondent’s motion that the Court previously refused to file and           
          (2) petitioner’s arguments at the hearing on respondent’s motion.           
               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            

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