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and prudent person, under the facts presented to the Court,
should have known that petitioner's claimed deductions could not
have been sustained, and petitioner knew that. This Court does
not and should not countenance the use of this Court as a vehicle
for disgruntled litigants to proclaim the wrongdoing of another,
his 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.
Petitioner, therefore, has interfered with the Court's function
to the detriment of other parties having cases with legitimate
issues for the Court to consider. Petitioner has 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
petitioner 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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Last modified: May 25, 2011