Steven John Rennie - Page 9




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          v. Connett, 908 F.2d 521, 525 (9th Cir. 1990).  Accordingly, we             
          find petitioner’s arguments to be specious and without merit.               
               From the transcript of petitioner’s Appeals conference, it             
          is clear that respondent’s Appeals officer met the letter and               
          spirit of the statutory requirement to provide a full and fair              
          hearing.  In addition, petitioner was provided with documents               
          that satisfied respondent’s verification requirement.                       
          Accordingly, we hold that respondent has not abused his                     
          discretion in determining to proceed with collection as set forth           
          in the March 1, 2001, Final Notice--Notice of Intent to Levy and            
          Notice of Your Right to a Hearing, sent to petitioner with                  
          respect to the 1998 tax liability.                                          
               Finally, respondent has moved for a penalty under section              
          6673 on the ground that petitioner’s arguments are frivolous and            
          that he instituted and maintained this proceeding merely for                
          delay.  Section 6673 provides that this Court may impose a                  
          penalty, not to exceed $25,000, where it finds that a taxpayer’s            
          position in the proceeding is frivolous and/or that the                     
          proceeding was instituted and maintained primarily for delay.               
          Section 6673 penalties may be imposed in a lien and levy case.              
          Pierson v. Commissioner, 115 T.C. 576, 580-581 (2000).                      
               In addition to questioning the authenticity of respondent’s            
          documentation, petitioner has interposed protester arguments                
          which have, on numerous occasions, been rejected by the courts.             






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