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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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