Michael Craig v. Commissioner - Page 21




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          collection action, or offer alternative means of collection.                
          These issues are now deemed conceded.  Rule 331(b)(4).                      
               For the foregoing reasons, we sustain respondent’s                     
          determination as to the proposed levy as a permissible exercise             
          of discretion.                                                              
          C.   Respondent’s Motion To Impose a Penalty Against Petitioner             
               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 such proceeding is frivolous or                      
          groundless.  We have repeatedly indicated our willingness to                
          impose such penalties in lien and levy review proceedings.                  
          Roberts v. Commissioner, 118 T.C. 365 (2002);  Hoffman v.                   
          Commissioner, T.C. Memo. 2000-198.  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.                                           
               In accordance with the firmly established law set forth                
          above, we conclude that petitioner’s positions in this proceeding           








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