Harold E. Call - Page 23

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          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. 576, 581                  
          (2000), 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                    
          imposition of the section 6673 penalty.  See, e.g., Craig v.                
          Commissioner, 119 T.C. at 264-265 (and cases cited thereat).                
               With respect to the instant matter, we are convinced that              
          petitioner instituted this proceeding primarily for delay.                  
          Throughout the administrative and trial process, petitioner                 
          advanced contentions and demands previously and consistently                
          rejected by this and other courts.  He submitted communications             
          quoting, citing, using out of context, and otherwise misapplying            
          portions of the Internal Revenue Code, regulations, Supreme Court           
          decisions, and other authorities.  While his procedural stance              
          concerning recording was correct, he ignored the Court’s explicit           
          warning that any further proceedings would be justified only in             
          the face of relevant and nonfrivolous issues.                               
               Moreover, petitioner was expressly alerted to the potential            
          use of sanctions in his case.  Yet he appeared at the trial                 






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