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position maintained by the taxpayer is “frivolous” where it is
“contrary to 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).
At trial, the Court repeatedly advised petitioner to address
the issues in, and present evidence regarding, his case. Instead
of presenting evidence or addressing the merits of his case,
petitioner belligerently shouted, yelled, and screamed irrelevant
questions repeatedly at the Court. Petitioner repeatedly
interrupted the Court and directed disrespectful statements to
the Court. Additionally, rather than directing his attention to
his case or the Court, petitioner shouted and called out to
approximately a dozen persons in the gallery disrespectful and
irrelevant remarks impugning the integrity of the Court.
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we
issued an unequivocal warning to taxpayers concerning the
imposition of penalties pursuant to section 6673(a) on those
taxpayers who abuse the protections afforded by sections 6320 and
6330 by instituting or maintaining actions under those sections
primarily for delay or by taking frivolous or groundless
positions in such actions. Petitioner filed multiple frivolous
documents with the Court. Petitioner’s position, based on stale
and meritless contentions, is manifestly frivolous and
groundless, and he has wasted the time and resources of this
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Last modified: November 10, 2007