Theodore Skeriotis - Page 9

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          there are no genuine issues of material fact and that respondent            
          is entitled to summary judgment as a matter of law.  On the basis           
          of our review of the record, we find that respondent did not                
          abuse his discretion in sustaining the tax lien.                            
               Section 6673(a)(1) authorizes the Tax Court to require a               
          taxpayer to pay to the United States a penalty no greater than              
          $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 proceedings is frivolous or                     
          groundless.  Although we do not impose a section 6673 penalty on            
          petitioner today, we strongly warn him that if he advances                  
          similar frivolous arguments in this Court in the future, we may             
          impose on him a section 6673 penalty up to the $25,000 maximum              
          allowable amount, even upon our own motion.                                 
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                
















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