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delay or that the taxpayer's position in such proceeding is
frivolous or groundless. The Court has indicated its willingness
to impose such penalty in lien and levy cases, Pierson v.
Commissioner, 115 T.C. 576, 580-581 (2000), and has in fact
imposed a penalty in several such cases, Roberts v. Commissioner,
118 T.C. (2002) (imposing a penalty in the amount of
$10,000); 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).
We are convinced petitioners instituted the present
proceeding primarily for delay. In this regard, it is clear that
petitioners regard this proceeding as nothing other than as a
vehicle to protest the tax laws of this country and to espouse
their 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.
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 petitioners pursuant to section
6673(a)(1) in the amount of $1,000.
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