- 20 - 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.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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