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arguments at the proceedings and in his brief. It is
inappropriate that taxpayers who promptly pay their taxes should
have the cost of Government and tax collection improperly
increased by citizens apparently unwilling to obey the law or
shoulder their assigned share of the Government cost.
This Court’s order of October 4, 2004, explicitly addressed
petitioner’s substantive arguments, stating:
As respondent correctly notes in the motion for
summary judgment, issues raised by petitioner during
the administrative process, i.e., in his request for a
collection due process hearing, have been repeatedly
rejected by this and other courts or are refuted by the
documentary record. Moreover the Court observes that
maintenance of similar arguments has served as grounds
for imposition of penalties under section 6673.
At the time of that order, the Court declined to grant
summary judgment or impose a section 6673 penalty because
respondent had denied petitioner the right to record the
administrative hearing, see Keene v. Commissioner, 121 T.C. 8
(2003), and as a result no face-to-face administrative conference
ever occurred. Thus, the Court afforded petitioner a trial and
at it an opportunity to raise any legitimate permitted issues,
but none were raised, and the previously addressed frivolous
issues were perpetuated. Hence, the Court concludes a section
6673 penalty of $2,500 shall be awarded to the United States in
this case.
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