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frivolous and groundless claims in a lien or levy proceeding, or
instituted that proceeding for the purpose of delay. Petitioner
also was advised of our decision in Davis v. Commissioner,
supra,3 wherein we imposed upon the taxpayer a $4,000 penalty
under section 6673, for advancing frivolous and groundless
claims. Pursuant to section 6673, we require petitioner to pay
to the United States a penalty of $3,500.
We have considered all arguments made by the parties and
have found those arguments not discussed herein to be irrelevant
and/or without merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
3 At the hearing the Appeals officer gave copies of above-
referenced cases to petitioner.
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Last modified: May 25, 2011