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However, in a collection review case, the Court may impose such a
penalty on its own motion. See Williams v. Commissioner, T.C.
Memo. 2002-111 (imposing sua sponte a penalty in the amount of
$1,000).
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 are 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.
Under the circumstances, we shall, on our own motion, impose
a penalty on petitioner pursuant to section 6673(a)(1) in the
amount of $1,000.
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.5
5 For example, petitioner’s allegation that he was not
offered an administrative hearing is belied by the Appeals
officer’s letters dated Jan. 30, 2001, and May 1, 2001, the first
of which was specifically referenced in the petition and a copy
attached as an exhibit. Moreover, petitioner’s allegation that
he was confused by “the various amounts sought” is explained, in
part, by the fact that petitioner’s liability changed with the
accrual of statutory interest (and the compounding thereof). See
(continued...)
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