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should have known that his arguments lacked merit. Petitioner
cited the Internal Revenue Code, the Tax Court Rules, the
Constitution, and dozens of cases. We have no doubt that
petitioner was or had reason to be thoroughly familiar with the
precedent which uniformly denied validity to his position.
Petitioner’s failure to provide respondent with information
requested and petitioner’s failure to offer competent evidence at
trial pertaining to substantive issues raised in the notice of
deficiency are further evidence that this lawsuit was instituted
primarily for delay. See Stamos v. Commissioner, 95 T.C. 624,
638 (1990), affd. without published opinion 956 F.2d 1168 (9th
Cir. 1992).
On the record before us, we are convinced that petitioner
has instituted and maintained this proceeding primarily for delay
and has advanced frivolous and groundless arguments. In the
light of the foregoing, we believe sanctions are necessary to
deter petitioner and other similarly situated taxpayers from
comparable dilatory conduct. Pursuant to section 6673(a)(1), we
impose against petitioner a penalty of $5,000.
We have considered all of petitioner’s contentions and
allegations that are not discussed herein, and we find them to be
without merit and/or irrelevant. To reflect the foregoing,
Decision will be entered
for respondent.
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