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Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir. 1986)). “‘The
inquiry is objective. If a person should have known that his
position is groundless, a court may and should impose
sanctions.’” Id.
Petitioner is a lawyer, admitted to practice before this
court. Nevertheless, his filings are studded with frivolous
arguments and groundless claims, mostly abandoned in favor of his
unsuccessful defense that we lack jurisdiction in this case. For
instance, in the petition, he makes the following claims: He is
a nonresident alien; he is not a citizen or resident of the
United States; he has no income subject to taxation by the United
States, and he has not withheld any moneys on behalf of any
Federal entity, resident, nonresident person, or entity. He adds
that, if the United States proved that the source of his income
was from a domestic corporation of the United States or is
otherwise directly connected to doing business in the United
States, then, since that would be new knowledge to him, it would
warrant abatement of the penalty and interest on the tax due. He
claims that the Secretary failed to notify him
that he was the recipient of “federal income” from a
“U.S. Corporation” that was synonymous in scope to the
“United States” [See 28 U.S.C. sec. 3002(15) (2000).]
and, therefore, petitioner would be compelled to
acknowledge that a “RETURN” of that income is required
under the local laws of the District of Columbia, the
IRC approved August 16, 1954, re-designated the IRC of
1986.
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