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delay in the collection process would be unconscionable.
Accordingly, we shall grant respondent’s Motion to Permit Levy.
II. Section 6673 Penalty
Section 6673(a)(1) authorizes the Tax 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 such proceeding is frivolous or
groundless. We warned taxpayers in Pierson v. Commissioner, 115
T.C. 576, 581 (2000), that abusing the procedural protections
afforded by sections 6320 and 6330 by pursuing frivolous lien or
levy actions for purposes of delaying the tax payment process
would result in sanctions under section 6673 when that section
was applicable. We have since repeatedly warned taxpayers
regarding section 6673, as we did petitioner here, and have
repeatedly disposed of cases premised on arguments akin to those
raised here summarily and with imposition of the section 6673
penalty. See Craig v. Commissioner, 119 T.C. 252, 265 (2002).
Petitioner was previously penalized for his frivolous
arguments and delay perpetrated on the Court in connection with
docket No. 13410-00 concerning his tax liability for the tax
years 1993 through 1997. Although in this action petitioner was
polite and eliminated several frivolous issues at trial, he
nevertheless wasted judicial resources on other frivolous
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