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groundless. The Court has indicated its willingness to impose
such penalty in lien and levy cases, Pierson v. Commissioner, 115
T.C. 576, 580-581 (2000), and has in fact imposed a penalty in a
number of such cases; see, e.g., Davich v. Commissioner, T.C.
Memo. 2002-255 (imposing a penalty in the amount of $5,000).
The petition in the present case advances some of the same
arguments that led to the imposition of a penalty in Davich v.
Commissioner, supra. Petitioners might therefore care to review
that case and consider whether it is in their interest to persist
in advancing such arguments.
In order to reflect the foregoing,
An appropriate order granting
respondent’s motion to dismiss for
lack of jurisdiction and to strike,
as supplemented, will be issued.
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Last modified: May 25, 2011