- 6 - 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 in both dockets petitioner’s position was frivolous and groundless and that petitioner instituted and maintained these proceedings primarily for delay. Although there were some minor differences between the frivolous and dilatory actions taken in each docket prior to consolidation, petitioner’s actions in both dockets merit similar penalties. Accordingly, pursuant to section 6673(a), we hold petitioner is liable for a $12,500 penalty in docket No. 20928-03 and a $12,500 penalty in docket No. 15561-04.Page: Previous 1 2 3 4 5 6 7 Next
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