Crevenne C. and Barbara A. Carrillo - Page 28

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          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 without             






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