-5-
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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