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raising the underlying tax liability as an issue. Sec.
6330(c)(2)(B).
Petitioner claims that she was denied her right to raise
relevant issues. The administrative record does not support her
claims. Although petitioner received a statutory notice of
deficiency for 1996, she was permitted to discuss her underlying
liability at her CDP hearing. She continued to make frivolous
arguments about the legality of Federal income taxes, and she
refused to discuss alternatives to the collection of her unpaid
tax liability. Accordingly, there was no abuse of discretion in
regard to whether petitioner was allowed to raise relevant issues
at her CDP hearing.
Section 6673 Penalty
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay a penalty not to exceed $25,000 if the taxpayer
took frivolous positions in the proceedings or instituted the
proceedings primarily for delay. A position maintained by the
taxpayer is “frivolous” where it is “contrary to established law
and unsupported by a reasoned, colorable argument for change in
the law.” Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir.
1986); Gilligan v. Commissioner, T.C. Memo. 2004-194. We have
consistently imposed section 6673 penalties in lien and levy
review cases where the taxpayer has raised frivolous and
groundless arguments as to the validity of our Federal income tax
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