Daniel E. Duncan - Page 12

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          to section 6673(a)(1).  Section 6673(a)(1) authorizes the Court             
          to require a taxpayer to pay to the United States a penalty in an           
          amount not to exceed $25,000 whenever it appears to the Court,              
          inter alia, that a proceeding before it was instituted or main-             
          tained primarily for delay, sec. 6673(a)(1)(A), or that the                 
          taxpayer’s position in such a proceeding is frivolous or ground-            
          less, sec. 6673(a)(1)(B).                                                   
               In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we               
          issued an unequivocal warning to taxpayers concerning the imposi-           
          tion 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            
               In the instant case, petitioner advances, we believe primar-           
          ily for delay, frivolous and/or groundless contentions, argu-               
          ments, and requests, 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 $2,500.                     
               We have considered all of petitioner’s contentions, argu-              
          ments, and requests that are not discussed herein, and we find              

               9The record in this case reflects that the settlement offi-            
          cer gave petitioner, inter alia, a copy of the Court’s opinion in           
          Pierson v. Commissioner, 115 T.C. 576 (2000).                               

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