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cognizable reason for doing so. Petitioner’s arguments in
support of his motion are that he objects to how his tax dollars
are being used, and he feels that respondent is seeking the
amount of his deficiency for an improper purpose. Petitioner
offered no evidence that respondent has acted improperly in this
case.
Discussion
This Court applies a stringent standard when considering
whether to vacate a judgment entered into by consent of the
parties. We have upheld such agreements unless the moving party
shows lack of formal consent, fraud, mistake, or a similar
ground. Dorchester Indus. Inc. v. Commissioner, 108 T.C. 320,
335 (1997), affd. without published opinion 208 F.3d 205 (3d Cir.
2000); Brewer v. Commissioner, T.C. Memo. 2005-10. Petitioner
has not argued that any of these or similar grounds are present
in this case. Furthermore, we are not inclined to allow
petitioner to withdraw his concessions where doing so will
prejudice respondent by increasing the cost of litigating this
case, particularly because petitioner conceded that respondent’s
determination was correct in order to avoid a trial. See Gale v.
Commissioner, T.C. Memo. 2002-54.
At this time we decline to impose sanctions under section
6673(a)(1). However, we warn petitioner that this Court is not
the appropriate forum for airing his personal grievances, and we
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Last modified: March 27, 2008