-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 advance
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