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whenever it appears to the Court, inter alia, that a proceeding
before it was instituted or maintained primarily for delay, sec.
6673(a)(1)(A), or that the taxpayer’s position in such a proceed-
ing is frivolous or groundless, sec. 6673(a)(1)(B).
In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we
issued an unequivocal warning to taxpayers concerning the imposi-
tion of a penalty under section 6673(a) on those taxpayers who
abuse the protections afforded by sections 6320 and 6330 by
instituting or maintaining actions under those sections primarily
for delay or by taking frivolous or groundless positions in such
actions.
In the instant case, petitioners advance, we believe primar-
ily for delay, frivolous and/or groundless contentions, argu-
ments, and requests, thereby causing the Court to waste its
limited resources. We shall impose a penalty on petitioners
pursuant to section 6673(a)(1) in the amount of $3,500.
We have considered all of petitioners’ contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and/or irrelevant.7
7We shall address petitioners’ allegation in the petition
that they “did not receive the Collection Due Process Hearing
Required by Internal Revenue Code Section 6330". That is be-
cause, according to petitioners, “The telephone [sic] hearing did
not meet the requirements of the law” as they were entitled to a
“face to face hearing as required by law”. The record estab-
lishes that the Appeals officer scheduled an Appeals Office
telephonic hearing for Dec. 20, 2000. The record also estab-
(continued...)
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