Robert R. Villwock - Page 16

                                       - 16 -                                         
          Memo. 2002-140 (imposing a penalty of $1,000); Newman v.                    
          Commissioner, T.C. Memo. 2002-135 (imposing a penalty of $1,000);           
          Yacksyzn v. Commissioner, T.C. Memo. 2002-99 (imposing a penalty            
          of $1,000); Watson v. Commissioner, T.C. Memo. 2001-213 (imposing           
          a penalty of $1,500); Davis v. Commissioner, T.C. Memo. 2001-87             
          (imposing a penalty of $4,000).                                             
               We are convinced that petitioner instituted the present                
          proceeding primarily for delay.  We note that, during the                   
          administrative process, the Appeals officer informed petitioner             
          of the Court’s opinion in Pierson v. Commissioner, supra.                   
          Petitioner nevertheless continued to press his meritless                    
          arguments.  Under the circumstances, 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.                                                               
               Under the circumstances, we shall grant that part of                   
          respondent’s motion that moves for the imposition of a penalty in           

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  Next

Last modified: May 25, 2011