Harvey Doyne Perry, Jr. - Page 17

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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. at 580-581, and has in fact imposed a                
          penalty in several such cases, Roberts v. Commissioner, supra;              
          Crow v. Commissioner, T.C. Memo. 2002-149 (imposing a penalty in            
          the amount of $1,500); Smeton v. Commissioner, T.C. Memo. 2002-             
          140 (imposing a penalty in the amount of $1,000); 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).                               
               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 is well aware of             
          the provisions of section 6673 as applicable to collection review           

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