Travis D. Hiland - Page 18

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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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