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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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