Danney R. Land - Page 18




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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.               
          E.g., Tolotti v. Commissioner, T.C. Memo. 2002-86.  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 $5,000.                                         
               In order to give effect to the foregoing,                              


                                             An appropriate order granting            
                                        respondent's motion, as                       
                                        supplemented, and decision for                
                                        respondent will be entered.                   















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