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petitioners knew that. We do not and should not countenance the
use of this Court as a vehicle for a disgruntled litigant to
proclaim the wrongdoing of another, their return preparer, as a
basis for relief from a penalty that was determined by respondent
on facts that clearly are not sustainable. Golub v.
Commissioner, T.C. Memo. 1999-288. Petitioners, therefore, have
interfered with the Court's function to the detriment of other
parties having cases with legitimate issues for the Court to
consider. Petitioners have caused needless expense and wasted
resources, not only for the Court, but for its personnel,
respondent, and respondent's counsel. Under these circumstances,
the penalty under section 6673 is warranted, and petitioners will
be ordered to pay a penalty of $500 to the United States under
section 6673(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011