Anthony M. Davich - Page 21

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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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