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a reasoned, colorable argument for change in the law.” Coleman
v. Commissioner, 791 F.2d 68, 71 (7th Cir. 1986) (imposing
penalties on taxpayers who made frivolous constitutional
arguments in opposition to the income tax). Courts have ruled
that tax protester arguments and defenses to the filing
requirement, such as petitioner has espoused, are groundless and
wholly without merit. Ginter v. Southern, 611 F.2d 1226, 1229
n.2 (8th Cir. 1979); see also Brunner v. Commissioner, T.C. Memo.
2004-187, affd. 142 Fed. Appx. 53 (3d Cir. 2005); Williams v.
Commissioner, T.C. Memo. 1999-277; Morin v. Commissioner, T.C.
Memo. 1999-240; Sochia v. Commissioner, T.C. Memo. 1998-294 (all
of which imposed a section 6673 penalty for tax protester
arguments).
Groundless litigation diverts the time and energies of
judges from more serious claims; it imposes needless
costs on other litigants. Once the legal system has
resolved a claim, judges and lawyers must move on to
other things. They cannot endlessly rehear stale
arguments. Both appellants say that the penalties
stifle their right to petition for redress of
grievances. But there is no constitutional right to
bring frivolous suits, see Bill Johnson’s Restaurants,
Inc. v. NLRB, 461 U.S. 731, 743, 103 S.Ct. 2161, 2170,
76 L.Ed.2d 277 (1983). People who wish to express
displeasure with taxes must choose other forums, and
there are many available. * * * [Coleman v.
Commissioner, supra at 72.]
Respondent informed petitioner at trial and by pretrial
memorandum of the Court’s ability to impose sanctions upon
petitioner for frivolous arguments pursuant to section 6673.
Furthermore, the Court warned petitioner that arguments against
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