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return and his withholding was limited. Throughout petitioner’s
dealings with respondent and the Court, he provided nothing but
specious and well-worn arguments, all of which represent nothing
more that a baseless collateral attack on the real question of
whether he had a Federal tax liability for 2002. The vast
majority of petitioner’s arguments have already been addressed by
this and other courts and are not worthy of further analysis by
this Court. The remainder are irrelevant to the question we
consider.
At trial, petitioner attempted to thwart the litigation
process by attempting to withdraw from his agreed stipulation at
the last minute. He presented no evidence or meaningful
testimony at the trial and merely forced respondent and the Court
to the expense and use of time to air his groundless and
sophistic technical arguments, all of which were designed to
delay the reporting and payment of petitioner’s 2002 tax
liability. Taxpayers, who have been issued a notice of
deficiency, have a right to avail themselves of this Federal tax
forum. Petitioner, by his failure to present evidence and the
frivolousness of his argument has abused that right. It appears
to the Court that the only reason petitioner pursued this
litigation is for the purpose of delay.
Under those aggravated circumstances, we hold that
petitioner is liable for a $10,000 penalty under section 6673.
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