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clear statement of error and contained “nothing more than
frivolous rhetoric and legalistic gibberish”).
Respondent also requests that this Court impose a penalty
pursuant to section 6673 because petitioner has instituted the
proceeding primarily for delay. Respondent further contends that
petitioner’s position is groundless or frivolous, and that
petitioner filed this petition as a protest to paying income
taxes.
Section 6673(a)(1) provides that this Court may require a
taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that: (1) The taxpayer instituted or
maintained the proceedings primarily for delay; (2) the
taxpayer’s position in the proceeding is groundless or frivolous;
or (3) the taxpayer unreasonably failed to pursue available
administrative remedies.
Petitioner has been notified repeatedly that this Court
might impose a penalty pursuant to section 6673(a)(1) if he
continued to assert frivolous arguments. Petitioner lodged with
the Court what he captioned a “Commercial notice of
administrative judgment by estoppel with respect to notice of
international commercial claim within the admiralty
administrative remedy agreement/contract file number LJF09092004
& UCC financing statement file number 05-7017217898” (commercial
notice). Attached to the commercial notice was a letter from the
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Last modified: May 25, 2011