Ronald W. Nelson, Jr. and Jennifer J. Nelson - Page 13




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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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