-6-
Therefore, we do not see any need to address those allegations.
See Crain v. Commissioner, 737 F.2d 1417, 1147 (5th Cir. 1984);
Craig v. Commissioner, 119 T.C. 252, 259-264 (2002) (and cases
cited thereat). We sustain respondent’s determination as to the
lien as a permissible exercise of discretion. We now turn to the
requested penalty under section 6673.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer’s position in the proceedings is frivolous or
groundless. We have repeatedly indicated our willingness to
impose such penalties in a lien and levy review case. Roberts v.
Commissioner, 118 T.C. 365 (2002). Moreover, we have imposed
penalties in such proceedings when the taxpayer has raised
frivolous and groundless arguments as to the legality of the
Federal tax laws. Yacksyzn v. Commissioner, T.C. Memo. 2002-99;
Watson v. Commissioner, T.C. Memo. 2001-213; Davis v.
Commissioner, T.C. Memo. 2001-87.
On the basis of the record, we believe that petitioner has
instituted and maintained these proceedings primarily for delay
and has advanced only frivolous and groundless shopworn
arguments. He was warned by Appeals at the hearing and was
advised by the Court in Hodgson v. Commissioner, T.C. Memo. 1998-
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