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delay or that the taxpayer's position in such proceeding is
frivolous or groundless. The Court has indicated its willingness
to impose such penalty in lien and levy cases, Pierson v.
Commissioner, 115 T.C. at 580-581, and has in fact imposed a
penalty in several such cases, Roberts v. Commissioner, supra;
Crow v. Commissioner, T.C. Memo. 2002-149 (imposing a penalty in
the amount of $1,500); Smeton v. Commissioner, T.C. Memo. 2002-
140 (imposing a penalty in the amount of $1,000); Newman v.
Commissioner, T.C. Memo. 2002-135 (imposing a penalty in the
amount of $1,000); Yacksyzn v. Commissioner, T.C. Memo. 2002-99
(imposing a penalty in the amount of $1,000); Watson v.
Commissioner, T.C. Memo. 2001-213 (imposing a penalty in the
amount of $1,500); Davis v. Commissioner, T.C. Memo. 2001-87
(imposing a penalty in the amount of $4,000).
We are convinced that petitioner instituted the present
proceeding primarily for delay. In this regard, it is clear that
petitioner regards this proceeding as nothing but a vehicle to
protest the tax laws of this country and to espouse his own
misguided views, which we regard as frivolous and groundless. In
short, having to deal with this matter wasted the Court's time,
as well as respondent's, and taxpayers with genuine controversies
may have been delayed.
Also relevant is the fact that petitioner is well aware of
the provisions of section 6673 as applicable to collection review
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