Michael L. Widner - Page 10

                                       - 10 -                                         
          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, 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.                                                        

Page:  Previous  1  2  3  4  5  6  7  8  9  10  

Last modified: May 25, 2011