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review of a collection action shall contain clear and concise
assignments of each and every error alleged to have been
committed in the notice of determination; any issue not raised in
the assignments of error shall be deemed conceded. See Lunsford
v. Commissioner, 117 T.C. 183, 185-186 (2001); Goza v.
Commissioner, 114 T.C. 176, 183 (2000). For completeness, we
have addressed various points advanced by petitioner during the
administrative process, but the items listed in section
6330(c)(2)(A) were not pursued even during those proceedings.
Accordingly, the Court concludes that respondent’s determination
to proceed with collection of petitioner’s tax liabilities was
not an abuse of discretion.
II. Section 6673 Penalty
Section 6673(a)(1) authorizes the Court to require the
taxpayer to pay a penalty not in excess of $25,000 when it
appears to the Court that, inter alia, proceedings have been
instituted or maintained by the taxpayer primarily for delay or
that the taxpayer’s position in such proceeding is frivolous or
groundless. In Pierson v. Commissioner, 115 T.C. at 581, we
warned that taxpayers abusing the protections afforded by
sections 6320 and 6330 through the bringing of dilatory or
frivolous lien or levy actions will face sanctions under section
6673. We have since repeatedly disposed of cases premised on
arguments akin to those raised herein summarily and with
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Last modified: May 25, 2011