- 13 -
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).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011