Malcolm Crow - Page 17




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          for the imposition of a penalty on petitioner under section 6673.           
               As relevant herein, section 6673(a)(1) authorizes the Tax              
          Court to require a taxpayer to pay to the United States a penalty           
          not in excess of $25,000 whenever it appears that proceedings               
          have been instituted or maintained by the taxpayer primarily for            
          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. 576, 580-581 (2000), and has in fact                 
          imposed a penalty in several such cases, Roberts v. Commissioner,           
          118 T.C.     (2002) (imposing a penalty in the amount of                    
          $10,000); 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           






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