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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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Last modified: May 25, 2011