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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.
E.g., Tolotti v. Commissioner, T.C. Memo. 2002-86. 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 the petitioner was made aware
of the fact that he could be subject to a penalty for instituting
or maintaining a lien or levy action primarily for delay or for
advancing frivolous or groundless arguments in such an action.
In this regard, the Appeals officer’s letter dated May 30, 2001,
expressly advised petitioner of Pierson v. Commissioner, supra,
and Davis v. Commissioner, T.C. Memo. 2001-87.
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 $5,000.
In order to give effect to the foregoing,
An appropriate order granting
respondent's motion, as
supplemented, and decision for
respondent will be entered.
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