William C. Stearman III - Page 6

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          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.                                                        



















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