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penalty in an amount not to exceed $25,000 in cases where it
appears to the Court that, inter alia, a proceeding before it was
instituted or maintained primarily for delay, sec. 6673(a)(1)(A),
or the taxpayer's position in such a proceeding is frivolous or
groundless, sec. 6673(a)(1)(B). In Pierson v. Commissioner, 115
T.C. 576, 581 (2000), we issued an unequivocal warning to taxpay-
ers concerning the imposition of a penalty under section 6673(a)
on those taxpayers who abuse the protections afforded by sections
6320 and 6330 by instituting or maintaining actions under those
sections primarily for delay or by taking frivolous or groundless
positions in such actions.
In the instant case, petitioner advances, we believe primar-
ily for delay, frivolous and groundless arguments and conten-
tions, thereby causing the Court to waste its limited resources.
We shall impose a penalty on petitioner pursuant to section
6673(a)(1) in the amount of $1,000.
We have considered all of petitioner’s arguments and conten-
tions which are not discussed herein, and we find them to be
without merit and/or irrelevant.
To reflect the foregoing,
An order granting respondent’s
motion and decision
sustaining respondent’s
determinations and imposing a
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