Robert E. Crandall - Page 20

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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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