-10- required under 26 U.S.C. � 6303(a).” Elias v. Connett, 908 F.2d 521, 525 (9th Cir. 1990). For the foregoing reasons, we sustain respondent’s determination as to the lien and 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 repeatedly indicated our willingness to impose such penalties in a lien and levy review case. Roberts v. Commissioner, supra. 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, supra; Watson v. Commissioner, T.C. Memo. 2001- 213; Davis v. Commissioner, T.C. Memo. 2001-87. Petitioner, we believe, has instituted and maintained this proceeding primarily for delay and has advanced only frivolous and groundless shopworn arguments. He was informed of our decision in Pierson v. Commissioner, 115 T.C. 576 (2000), wherein we stated unequivocally that we would not hesitate to impose penalties under section 6673 against taxpayers who advancePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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