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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 $3,200.
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.5
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An appropriate order granting
respondent’s motion and decision
will be entered for respondent.
5We note that petitioners allege in the petition that, “by
not allowing Petitioner to make an adequate record of the CDP
hearing”, respondent violated sec. 7521(a)(1). We shall not
address petitioners’ allegation. That is because, assuming
arguendo that sec. 7521(a)(1) were applicable in the case of an
Appeals Office hearing under sec. 6330(b)(1), the record does not
establish that petitioners complied with the requirement of sec.
7521(a)(1) that they present respondent with their request to
make an audio recording of their Appeals Office hearing in
advance of that hearing.
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Last modified: May 25, 2011