Lucinda A. Yazzie - Page 20

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          on arguments akin to those raised herein summarily and with                 
          imposition of the section 6673 penalty.  See, e.g., Craig v.                
          Commissioner, 119 T.C. at 264-265 (and cases cited thereat).                
               With respect to the instant matter, we are convinced that              
          petitioner instituted this proceeding primarily for delay.                  
          Throughout the administrative and pretrial process, petitioner              
          advanced contentions and demands previously and consistently                
          rejected by this and other courts.  She submitted lengthy                   
          communications quoting, citing, using out of context, and                   
          otherwise misapplying portions of the Internal Revenue Code,                
          regulations, court decisions, and other authorities.  Moreover,             
          petitioner was, before this case was filed, explicitly alerted to           
          Pierson v. Commisssioner, supra, and use of sanctions in                    
          analogous situations.                                                       
               Hence, petitioner received fair warning but has persisted in           
          frivolously disputing respondent’s determination.  The Court                
          concludes that a penalty of $2,000 should be awarded to the                 
          United States in this case.  To reflect the foregoing,                      

                                                  An appropriate order                
                                             granting respondent’s motion             
                                             and decision for respondent              
                                             will be entered.                         








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