John Thurman Horejs - Page 13

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          frivolous or groundless.  The Court has indicated its willingness           
          to impose such penalty in lien and levy cases, Pierson v.                   
          Commissioner, 115 T.C. at 580-581 (2000), and has in fact imposed           
          a penalty in several such cases, Roberts v. Commissioner, supra             
          (imposing a penalty in the amount of $10,000); Newman v.                    
          Commissioner, T.C. Memo. 2002-135 (imposing a penalty in the                
          amount of $1,000); Yacksyzn v. Commissioner, T.C. Memo. 2002-99             
          (imposing a penalty in the amount of $1,000); Watson v.                     
          Commissioner, T.C. Memo. 2001-213 (imposing a penalty in the                
          amount of $1,500); Davis v. Commissioner, T.C. Memo. 2001-87                
          (imposing a penalty in the amount of $4,000).                               
               The Appeals Office provided petitioner with a copy of the              
          Court’s opinion in the Pierson case during the administrative               
          process.  Under the circumstances, we are convinced that                    
          petitioner instituted the present proceeding primarily for delay.           
          In this regard, it is clear that petitioner regarded 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.                                                               
               Accordingly, we shall grant that part of respondent’s motion           
          that moves for the imposition of a penalty in that we shall                 

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