Richard Hamzik - Page 5

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          Memo. 2003-144; Michael v. Commissioner, supra; Burnett v.                  
          Commissioner, T.C. Memo. 2002-181, affd. 67 Fed. Appx. 248                  
          (5th Cir. 2003); Reichenbach v. Commissioner, T.C. Memo.                    
          1995-369, affd. without published opinion 99 F.3d 1139 (6th Cir.            
          1996).  We shall not painstakingly address those assertions “with           
          somber reasoning and copious citation of precedent; to do so                
          might suggest that these arguments have some colorable merit.”              
          Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).                 
          Suffice it to say that petitioner has not persuaded us that any             
          part of respondent’s determination is incorrect.  We conclude               
          that respondent may proceed with his proposed levy for 1999.                
               As to respondent’s request to impose a sanction against                
          petitioner, section 6673(a)(1) authorizes this Court to require a           
          taxpayer to pay to the United States a penalty not in excess of             
          $25,000 whenever it appears that proceedings have been instituted           
          or maintained by the taxpayer primarily for delay or that the               
          taxpayer’s position in the proceeding is frivolous or groundless.           
          We have repeatedly indicated our willingness to impose such                 
          penalties in a lien and levy review case.  E.g., Roberts v.                 
          Commissioner, supra at 372-373; Pierson v. Commissioner, 115 T.C.           
          576, 581 (2000).  In addition, we have imposed section 6673(a)(1)           
          penalties in lien and levy review cases where, as here, the                 
          taxpayer has raised frivolous and groundless arguments as to the            
          validity of our Federal income tax system.  See, e.g., Gilligan             






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