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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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