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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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