Michael D. Keown and Rosann C. Keown - Page 9

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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            
               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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