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Petitioner’s only argument is that he believed that he did
not have an opportunity to challenge any of the “hearsay or
secondary information” that was presented at trial.
As was explained to petitioner at trial, he had the
opportunity to call his own witnesses, offer any documents, and
present his own testimony, but he chose not to do so. As
discussed, he was not prejudiced by not receiving the documents
presented by respondent until trial. Moreover, sanctions of
$10,000 have previously been imposed against petitioner for the
1994, 1995, and 1996 tax years for advancing the same arguments
as he has in this case. See Rodriguez v. Commissioner, T.C.
Memo. 2003-105. The opinion admonishing petitioner for his
previous conduct in 3 taxable years was filed on April 17, 2003.
Id. Nonetheless, petitioner had the audacity to once again
petition the Court to redetermine his tax liability for
4 subsequent taxable years less than 3 months later, on July 1,
2003, and to continue to submit the same baseless arguments in
this case as had been presented in his earlier case.
In his prior case, as in this case, petitioner was warned
before trial by respondent and during trial by the Court that his
position would warrant a penalty of up to $25,000. Petitioner’s
arguments are the same frivolous and groundless arguments that we
previously found were instituted primarily for delay. Petitioner
continues in his failure to cooperate with respondent and to
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