- 28 - 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, and despite petitioners’ denials in their objection to respondent’s motion for summary judgment, we are convinced that petitioners instituted this proceeding primarily for delay. Throughout the administrative and litigation process, petitioners advanced contentions and demands previously and consistently rejected by this and other courts. They submitted lengthy communications quoting, citing, using out of context, and otherwise misapplying portions of the Internal Revenue Code, regulations, Supreme Court decisions, and other authorities. While their procedural stance concerning recording was correct, they ignored the Court’s explicit warning that any further proceedings would be justified only in the face of relevant and nonfrivolous issues. Moreover, petitioners were, on multiple occasions, expressly alerted to the potential use of sanctions in their case. Yet Mr. Carrillo appeared at the trial session in Las Vegas withoutPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011