Randy S. Quigley - Page 13

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          or maintaining actions under those sections primarily for delay              
          or by taking frivolous or groundless positions in such actions.              
          In the Appeals officer’s January 5, 2004 letter, the Appeals                 
          officer advised petitioner that “the courts have consistently and            
          repeatedly rejected the arguments expressed in your letters and              
          in many cases have imposed sanctions.”  In that letter, the                  
          Appeals officer also advised petitioner of the holding in Pierson            
          v. Commissioner, supra, and provided petitioner with a list of               
          other cases in which a penalty under section 6673(a)(1) had been             
          imposed.  Nonetheless, in the instant case, petitioner alleged in            
          the petition and advances in petitioner’s response, we believe               
          primarily for delay, frivolous and/or groundless statements,                 
          contentions, arguments, and requests, thereby causing the Court              
          to waste its limited resources.  We shall impose a penalty on                
          petitioner pursuant to section 6673(a)(1) in the amount of                   
          $1,000.                                                                      
               We have considered all of petitioner’s statements, conten-              
          tions, arguments, and requests that are not discussed herein, and            
          we find them to be without merit and/or irrelevant.10                        

               10We shall, however, address one of petitioner’s contentions            
          in petitioner’s response.  Petitioner contends in petitioner’s               
          response that the Appeals officer refused “to afford petitioner              
          the CDP hearing".  On the record before us, we disagree.  In the             
          Appeals officer’s February 6, 2004 letter, the Appeals officer               
          informed petitioner that “If you wish to have a face-to-face                 
          conference, please write me within 15 days from the date of this             
          letter * * * and describe the legitimate issues you will dis-                
                                                              (continued...)           





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