Eugene I. and Leonarda T. Valdez - Page 10




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          proclaim the wrongdoing of another, their return preparer, as a             
          basis for relief from penalties that were determined by                     
          respondent on facts that clearly are not sustainable.  Golub v.             
          Commissioner, T.C. Memo. 1999-288.  Petitioners, therefore, have            
          interfered with the Court's function to the detriment of other              
          parties having cases with legitimate issues for the Court to                
          consider.  Petitioners have caused needless expense and wasted              
          resources, not only for the Court, but for its personnel,                   
          respondent, and respondent's counsel.  Under these circumstances,           
          the penalty under section 6673 is warranted, and petitioners will           
          be ordered to pay a penalty of $500 to the United States under              
          section 6673(a).                                                            
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   




                                             Decision will be entered                 
                                        for respondent.                               
















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