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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
frivolous).
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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