James S. Zigmont - Page 12

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          established law and unsupported by a reasoned, colorable argument           
          for change in the law.”  Coleman v. Commissioner, 791 F.2d 68, 71           
          (7th Cir. 1986).                                                            
               Respondent has not asked the Court to impose a penalty under           
          section 6673(a)(1), and the Court declines to impose such a                 
          penalty.  At the hearing the Court warned petitioner that he                
          would be subject to a section 6673(a)(1) penalty if he continued            
          to raise frivolous arguments and cause further delays.                      
          Petitioner heeded the Court’s warning.  The Court, therefore,               
          concludes that it is not appropriate to impose a penalty in the             
          instant case, but the Court explicitly admonishes petitioner that           
          he may, in the future, be subject to a penalty under section 6673           
          for any proceedings instituted or maintained primarily for delay            
          or for any proceedings which are frivolous or groundless.                   
               The Court has considered all of petitioner’s contentions,              
          arguments, requests, and statements.  To the extent not discussed           
          herein, we conclude that they are meritless, moot, or irrelevant.           
               To reflect the foregoing,                                              


                                             An appropriate order and                 
                                        decision will be entered.                     











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