-10-
supra. Moreover, petitioners had an opportunity to petition this
Court to dispute the liability reflected in the notice of
deficiency, but chose not to do so.
Petitioners argue further that they did not receive notice
and demand for payment. We disagree. Petitioners received
numerous notices, including the final notice. These notices
satisfied requirements of section 6303(a) by informing
petitioners of the amount owed and by requesting payment. Hughes
v. United States, supra at 531.
Petitioners argue lastly that respondent assessed a section
6702 frivolous penalty for 1997. Petitioners are mistaken. The
only penalty assessed by respondent is an accuracy-related
penalty under section 6662(a).
For the foregoing reasons, we sustain respondent’s
determination as to the proposed levy as a permissible exercise
of discretion. 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 indicated our willingness to impose such
penalties in collection review cases. Roberts v. Commissioner,
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