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at issue in the appeal and the Court determines that good cause
is shown not to suspend the levy.
We have already concluded that petitioner is barred under
section 6330(c)(2)(B) from challenging the existence or amount of
his underlying tax liabilities for 1983 and 1993 to 1995 in this
proceeding. See Goza v. Commissioner, 114 T.C. at 180. In
addition, respondent has shown good cause why the levy should no
longer be suspended. In short, as was the case in Burke v.
Commissioner, supra, petitioner has used the collection review
procedure primarily as a device to needlessly delay collection.
Petitioner is no stranger to the Court. As outlined above, he
abused the Court’s procedures in the deficiency cases at docket
Nos. 20474-90, 18627-97, and 6546-00. Petitioner’s arguments in
this case lacked any merit. Considering all the circumstances,
we see no justification for further delaying the collection
process. Accordingly, we shall grant respondent’s Motion to
Permit Levy.
II. Section 6673 Penalty
Section 6673(a)(1) authorizes the Tax 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 such proceeding is frivolous or
groundless. We warned taxpayers in Pierson v. Commissioner, 115
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