at 4. This finding of bad faith is amply supported by the record: Sauers admitted that he could not present facts to challenge the Commissioner’s determination of tax deficiency, he refused to engage in a stipulation of facts, and his legal arguments have been repeatedly rejected by the courts. See, e.g., Welch v. Helvering, 290 U.S. 111, 54 S.Ct. 8, 78 L.Ed. 212 (1933) (establishing that burden of proof in Tax Court is on the taxpayer); Nash Miami Motors, Inc. v. Commissioner, 358 F.2d 636 (5th Cir.), cert. denied, 385 U.S. 918, 87 S.Ct. 227, 17 L.Ed.2d 142 (1966) (relying on Ex parte Bakelite Corp., 279 U.S. 438, 49 S.Ct. 411, 73 L.Ed. 789 (1929) for the conclusion that the statute establishing the Tax Court does not unconstitutionally violate separation of powers); Larsen at 941-942 (<HOLDING>); Wright v. Commissioner, 752 F.2d 1059, 1062
holding no first amendment right to file frivolous grievances holding that the court of claims did not have jurisdiction over plaintiffs first amendment claim of improper removal holding that article iii courts have an independent obligation to determine whether subject matter jurisdiction exists holding the following claims to be frivolous  6673 infringes upon first amendment right to petition tax court cannot have jurisdiction because it is not an article iii court holding that the bankruptcy courts jurisdiction to adjudicate common law claims violated article iii without deciding the claims