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her fifth argument because there is no requirement that the
notice of intent to levy or the Appeals officer identify the Code
sections which establish the taxpayer’s liability for tax,
additions to tax, or penalties. Nestor v. Commissioner, supra at
167. We conclude that petitioner had a fair hearing under
section 6330(b) and that respondent’s determination to proceed
with collection of her 1993 and 1994 tax liabilities was not an
abuse of discretion.
C. Whether Petitioner Instituted or Maintained Proceedings
Primarily for Delay or Whether Petitioner’s Position Is
Frivolous or Groundless
The Court may require a taxpayer to pay a penalty to the
United States of not more than $25,000 if the taxpayer instituted
or maintained proceedings primarily for delay, if the taxpayer’s
position is frivolous or groundless, or if the taxpayer
unreasonably failed to pursue administrative remedies. Sec.
6673(a). Petitioner contends that her argument is not frivolous
and that she did not use this case for delay. We disagree.
A taxpayer’s position is frivolous or groundless if it is
contrary to established law and unsupported by a reasoned,
colorable argument for change in the law. Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986). Petitioner’s
contention that respondent must identify the Code sections which
establish her liability for tax is frivolous. Nestor v.
Commissioner, supra. Her argument that she was not the taxpayer
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