Lance Standifird - Page 11




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          groundless.  We have repeatedly indicated our willingness to                
          impose such penalties in collection review cases.  Roberts v.               
          Commissioner, supra.  In Pierson v. Commissioner, 115 T.C. 576              
          (2000), taxpayers advancing frivolous and groundless claims and             
          instituting proceedings under section 6330(d) for the purposes of           
          delay were given unequivocal warning that the Court would impose            
          penalties.  See also Hoffman v. Commissioner, T.C. Memo. 2000-              
          198.  Moreover, we have imposed penalties in such proceedings               
          when the underlying tax liability was not at issue and the                  
          taxpayer raised frivolous and groundless arguments as to the                
          legality of the Federal tax laws.  Yacksyzn v. Commissioner,                
          supra; Watson v. Commissioner, T.C. Memo. 2001-213; Davis v.                
          Commissioner, T.C. Memo. 2001-87.                                           
               Petitioner is a frequent litigator of groundless challenges            
          to the validity of the Internal Revenue Code.  See, e.g.,                   
          Standifird v. United States, 41 Fed. Appx. 99 (9th Cir. 2002);              
          Standifird v. Augustine, 74 AFTR 2d 94-5447, 94-2 USTC par.                 
          50,530 (D. Ariz. 1994); Standifird v. United States, 32 Fed. Cl.            
          731 (1995).  In a prior proceeding, this Court imposed upon                 
          petitioner a penalty under section 6673 of $2,500.  Standifird v.           
          Commissioner, T.C. Memo. 1995-348.  Petitioner, however,                    
          continues to advance the same type of frivolous and groundless              
          arguments as in the previous cases.                                         








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