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proceedings such as the present one. In this regard, petitioner
was provided at the administrative hearing on July 26, 2001, with
a copy of this Court’s opinion in Pierson v. Commissioner, supra,
in which the Court indicated its willingness to impose the
section 6673 penalty in lien and levy cases.
Under the circumstances, we shall grant that part of
respondent’s motion that moves for the imposition of a penalty in
that we shall impose a penalty on petitioner pursuant to section
6673(a)(1) in the amount of $2,500.
In order to give effect to the foregoing,
An appropriate order granting
respondent's motion and decision
for respondent will be entered.
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Last modified: May 25, 2011