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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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