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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, petitioner advances, 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 petitioner
pursuant to section 6673(a)(1) in the amount of $600.
We have considered all of petitioner’s contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and/or irrelevant.8
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and decision will be entered
for respondent.
8In petitioner’s response to respondent’s motion, petitioner
argues that the Appeals Office erred in denying him the opportu-
nity to make an audio recording of his Appeals Office hearing
held on Oct. 3, 2002. The record establishes that petitioner
and/or Ms. Flathers made an audio recording of petitioner’s
Appeals Office hearing, and we shall not address petitioner’s
argument about the Appeals Office’s refusal to permit him to
record that hearing.
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Last modified: May 25, 2011