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We are convinced that petitioner instituted the present
proceeding primarily for delay. In this regard, it is clear that
petitioner regards 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.
Also relevant is the fact that petitioner was informed of
the provisions of section 6673 as applicable to collection review
proceedings such as the present one. In this regard, petitioner
was provided at the administrative hearing on February 6, 2002,
with a copy of this Court’s opinion in Pierson v. Commissioner,
supra, in which the Court indicated its willingness to impose the
section 6673 penalty in lien and levy cases.
Under the circumstances, we shall, on our own motion, impose
a penalty on petitioner pursuant to section 6673(a)(1) in the
amount of $5,000.
C. Conclusion
We have considered all of petitioner’s arguments that are
not discussed herein, and we find them to be without merit and/or
irrelevant.
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