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As relevant herein, section 6673(a)(1) authorizes the Tax
Court to require a taxpayer to pay to the United States a penalty
not in excess of $25,000 whenever it appears that proceedings
have been instituted or maintained by the taxpayer primarily for
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 a number of such cases.8
We are convinced that petitioners instituted the present
proceeding primarily for delay. In this regard, it is clear that
petitioners regard this proceeding as nothing but a vehicle to
protest the tax laws of this country and to espouse their own
misguided views, which we regard as frivolous and groundless.
E.g., Tolotti v. Commissioner, T.C. Memo. 2002-86. In short,
8 E.g., Roberts v. Commissioner, 118 T.C. 365 (2002)
(imposing a penalty in the amount of $10,000); Schroeder v.
Commissioner, T.C. Memo. 2002-190 (imposing sua sponte a penalty
in the amount of $1,000); Wagner v. Commissioner, T.C. Memo.
2002-180 (imposing a penalty in the amount of $4,000); Perry v.
Commissioner, T.C. Memo. 2002-165 (imposing a penalty in the
amount of $2,500); 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); Williams v.
Commissioner, T.C. Memo. 2002-111 (imposing sua sponte 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).
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