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generated and do not exist in hard copy.” Pursifull v. United
States, supra at 601; Bassett v. United States, 782 F. Supp. 113,
117 (M.D. Ga. 1992). Accordingly, we hold that respondent did
not abuse his discretion with respect to the determination to
proceed with collection.
Respondent has also moved that petitioner be held liable for
a penalty under section 6673 on the ground that his arguments are
frivolous and that he instituted and maintained this proceeding
primarily for delay. Section 6773 provides that this Court may
impose a penalty, not to exceed $25,000, where it is found that a
taxpayer’s position in the proceeding is frivolous and/or that
the proceeding was instituted and maintained primarily for delay.
Section 6673 penalties may be imposed in a lien and levy case.
Pierson v. Commissioner, 115 T.C. 576, 580-581 (2000).
In addition to questioning the authenticity of respondent’s
documentation, petitioner has interposed other protester
arguments which have, on numerous occasions, been rejected by the
courts. In order to support his arguments, petitioner has
selectively picked phrases out of context from statutes and/or
opinions. In so doing, petitioner has chosen to ignore more
current or complete statements of the law. Petitioner has
ignored the rules and regulations and contends that he is not
required to comply with or pay attention to respondent’s letters
and determinations. Petitioners’ arguments are superficial and
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