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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, supra 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 pretrial 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, on multiple occasions, expressly
alerted to the potential use of sanctions in his case. Yet he
appeared at the trial session in Las Vegas without any legitimate
evidence or argument in support of his position. He instead
continued to espouse those positions that had been explicitly
addressed and rejected in this Court’s order of November 17,
2004, or in other cases previously decided by the Court. The
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