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not and should not countenance the use of this Court as a vehicle
for disgruntled litigants to proclaim the wrongdoing of another,
his return preparer, as a basis for relief from penalties that
were determined by respondent on facts that clearly are not
sustainable. Golub v. Commissioner, T.C. Memo. 1999-288.
Petitioners, therefore, have interfered with the Court's function
to the detriment of other parties having cases with legitimate
issues for the Court to consider. Petitioners have caused
needless expense and wasted resources, not only for the Court,
but for its personnel, respondent, and respondent's counsel.
Under these circumstances, the penalty under section 6673 is
warranted, and petitioners will be ordered to pay a penalty of
$500 to the United States under section 6673(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011