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Office for another hearing under section 6330(b) in order to
allow petitioners to make such an audio recording, see Lunsford
v. Commissioner, 117 T.C. 183, 189 (2001), and (2) it is not
necessary or appropriate to reject respondent’s determination to
proceed with the collection action as determined in the notices
of determination with respect to petitioners’ unpaid liabilities
for taxable years 1995, 1996, 1997, and 1998, see id.
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining to proceed with the collection action as determined
in the notices of determination with respect to petitioners’
unpaid liabilities for taxable years 1995, 1996, 1997, and 1998.
In respondent’s motion, respondent requests that the Court
require petitioners to pay a penalty to the United States pursu-
ant to section 6673(a)(1). Section 6673(a)(1) authorizes the
Court to require a taxpayer to pay to the United States a penalty
in an amount not to exceed $25,000 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 proceeding is frivolous or ground-
less, 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
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