Michael White - Page 11

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          the penalties under section 6662(a).  Any reasonable and prudent            
          person, under the facts presented to the Court, should have known           
          that the claimed deductions could not have been sustained, and              
          petitioner knew that.  We do not and should not countenance the             
          use of this Court as a vehicle for a disgruntled litigant to                
          proclaim the wrongdoing of another, his return preparer, as a               
          basis for relief from a penalty that was 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               

                                             Decision will be entered                 
                                        under Rule 155.                               

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Last modified: May 25, 2011