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raised in the assignments of error shall be deemed conceded. See
Lunsford v. Commissioner, 117 T.C. 183, 185-186 (2001); Goza v.
Commissioner, 114 T.C. 176, 183 (2000). Accordingly, the Court
concludes that respondent’s determination to proceed with
collection of petitioner’s tax liabilities was not an abuse of
discretion.
II. Section 6673 Penalty
Section 6673(a)(1) authorizes the Court to require the
taxpayer to pay a penalty not in excess of $25,000 when it
appears to the Court that, inter alia, proceedings have been
instituted or maintained by the taxpayer primarily for delay or
that the taxpayer’s position in such proceeding is frivolous or
groundless. In Pierson v Commissioner, 115 T.C. 576, 581 (2000),
we warned that taxpayers abusing the protections afforded by
sections 6320 and 6330 through the bringing of dilatory or
frivolous lien or levy actions will face sanctions under section
6673. We have since repeatedly disposed of cases premised on
arguments akin to those raised herein summarily and with
imposition of the section 6673 penalty. See, e.g., Craig v.
Commissioner, supra at 264-265 (and cases cited thereat).
With respect to the instant matter, we are convinced that
petitioner instituted this proceeding primarily for delay by
advancing contentions previously and consistently rejected by
this and other courts. We note that during petitioner’s hearing
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