Brian Timothy Brunner - Page 13

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               petition for redress of grievances.  But there is no                   
               constitutional right to bring frivolous suits, see Bill                
               Johnson’s Restaurants, Inc. v. NLRB, 461 U.S. 731, 743, 103            
               S.Ct. 2161, 2170, 76 L.Ed.2d 277 (1983).  People who wish to           
               express displeasure with taxes must choose other forums, and           
               there are many available. * * * [Coleman v. Commissioner,              
               supra at 72.]                                                          
          The Court is satisfied that a penalty in this case is                       
          appropriate, and, therefore, chooses to exercise its discretion             
          sua sponte under section 6673(a)(1) in requiring petitioner to              
          pay a penalty in the amount of $1,000 to the United States.                 
               To reflect the foregoing,                                              


                                                  An appropriate decision             
                                             will be entered for respondent           
                                             with respect to the deficiency           
                                             and additions to tax under               
                                             sections 6651(a)(1) and 6654             
                                             and imposing a penalty under             
                                             6673(a)(1) and to reflect                
                                             concessions made by                      
                                             respondent, for petitioner               
                                             with respect to additions to             
                                             tax under section 6651(a)(2).            











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