Jonathan Harris - Page 5

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          the taxpayer primarily for delay or that the taxpayer's position            
          in such proceeding is frivolous or groundless.  A taxpayer’s                
          position is frivolous or groundless if it is “‘contrary to                  
          established law and unsupported by a reasoned, colorable argument           
          for change in the law.’”  Williams v. Commissioner, 114 T.C. 136,           
          144 (2000) (quoting Coleman v. Commissioner, 791 F.2d 68, 71 (7th           
          Cir. 1986)).  We find that petitioner has advanced frivolous and            
          groundless statements, contentions, and arguments.  We further              
          find that petitioner has instituted this proceeding primarily for           
          delay.  Under the circumstances presented, we shall impose on               
          petitioner a penalty in the amount of $5,000.                               
               To reflect the foregoing,                                              
                                             An appropriate order of                  
                                             dismissal and decision will be           
                                             entered for respondent.                  




















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