David and Theresa Smeton - Page 16




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          Commissioner, 115 T.C. 576, 580-581 (2000), and has in fact                 
          imposed a penalty in several such cases, Roberts v. Commissioner,           
          supra (imposing a penalty in the amount of $10,000); Newman v.              
          Commissioner, T.C. Memo. 2002-    (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 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.  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 petitioners pursuant to section           
          6673(a)(1) in the amount of $1,000.                                         











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