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We are convinced that petitioner instituted the present
proceeding primarily for delay. In this regard, 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.
E.g., Tolotti v. Commissioner, T.C. Memo. 2002-86. 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.
Also relevant is the fact that the petitioner was made aware
of the fact that he could be subject to a penalty for instituting
or maintaining a lien or levy action primarily for delay or for
advancing frivolous or groundless arguments in such an action.
In this regard, the Appeals officer’s letter dated April 22,
2002, furnished petitioner with a copy of Davis v. Commissioner,
T.C. Memo. 2001-87, a case in which this Court imposed on the
taxpayer a $4,000 penalty pursuant to section 6673(a) for making
frivolous and groundless arguments in a collection review
7(...continued)
Commissioner, T.C. Memo. 2002-316 (imposing a penalty in the
amount of $2,500); Kiley v. Commissioner, T.C. Memo. 2002-315
(imposing a penalty in the amount of $5,000); Rennie v.
Commissioner, T.C. Memo. 2002-296 (imposing a penalty in the
amount of $1,500); Tornichio v. Commissioner, T.C. Memo. 2002-291
(imposing a penalty in the amount of $12,500); Keene v.
Commissioner, T.C. Memo. 2002-277 (imposing a penalty in the
amount of $5,000), and numerous other cases cited therein at
n.14.
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