Willie R. Davidson - Page 16




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          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.  During the administrative                  
          hearing, petitioner was provided with a copy of the Court’s                 
          opinion in Pierson v. Commissioner, supra, and was warned that              
          his arguments were frivolous.  In this regard, it is clear that             
          petitioner instituted and maintained 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 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.                                        
               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 $4,000.                                         
               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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