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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. After all, petitioner attached
to his petition and/or motion to dismiss a copy of Davis v.
Commissioner, T.C. Memo. 2001-87, in which this Court sustained
the Commissioner’s determination to proceed with collection and
imposed a $4,000 penalty under section 6673(a) against the
taxpayer. Moreover, in its Order dated December 20, 2001,
denying his motion to dismiss, the Court expressly warned
petitioner about the possibility of imposing a penalty under
section 6673.
Under the circumstances, we shall grant that part of
respondent’s motion that moves for the imposition of a penalty in
that we shall impose a penalty on petitioner pursuant to section
6673(a)(1) in the amount of $1,500.
In order to give effect to the foregoing,
An appropriate order granting
respondent's motion and decision
for respondent will be entered.
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Last modified: May 25, 2011