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imposition of the section 6673 penalty. See, e.g., Craig v.
Commissioner, 119 T.C. at 264-265 (and cases cited thereat).
With respect to the instant matter, we are convinced that
petitioner instituted this proceeding primarily for delay.
Throughout the administrative and pretrial process, petitioner
advanced contentions and demands previously and consistently
rejected by this and other courts. He submitted lengthy
communications quoting, citing, using out of context, and
otherwise misapplying portions of the Internal Revenue Code,
regulations, court decisions, and other authorities. Moreover,
petitioner was explicitly alerted to Pierson v. Commissioner,
supra, and the use of sanctions in analogous situations.
Hence, petitioner received fair warning but has persisted in
frivolously disputing respondent’s determination. The Court sua
sponte concludes that a penalty of $1,000 should be awarded to
the United States in this case. To reflect the foregoing,
An appropriate order
granting respondent’s motion
and decision for respondent
will be entered.
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