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frivolous and groundless litigation in this Court, and the
warnings he has received in previous administrative and judicial
proceedings regarding the consequences of pursuing frivolous and
groundless arguments. Petitioner repeatedly has failed to file
Federal income tax returns. He participated in administrative
proceedings before the Internal Revenue Service and filed several
cases in this Court in which he challenged the legitimacy of the
tax system and repeatedly questioned his obligation to file tax
returns. See Keenan v. Commissioner, T.C. Memo. 2006-45; Keenan
v. Commissioner, T.C. Memo. 1998-388. During the previous
administrative and judicial proceedings and the section 6330
hearing in this case, petitioner was warned of the consequences
that may attach to his conduct challenging the tax system. See,
e.g., Keenan v. Commissioner, T.C. Memo. 2006-45. Despite the
warnings, petitioner has continued to challenge the validity of
the tax system and of the assessments at issue in this case.
Consequently, we shall require petitioner to pay to the United
States a penalty under section 6673(a)(1) of $15,000.
Other arguments raised by petitioner have been considered
and are rejected as meritless.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011