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1111, 1119-1122 (1983); Tolotti v. Commissioner, T.C. Memo. 2002-
86, affd. 70 Fed. Appx. 971 (9th Cir. 2003). We find that
respondent did not abuse his discretion in denying petitioner’s
collection alternative.
In the notice of determination, respondent verified that all
requirements of applicable law and administrative procedure had
been met and that respondent properly balanced the need for
efficient collection against any legitimate concerns raised by
petitioner. Petitioner has not presented any evidence or
persuasive arguments to convince us that respondent abused his
discretion but instead has only advanced frivolous tax protester-
type arguments. As a result, we hold respondent’s determination
was not an abuse of discretion, and respondent may proceed with
the proposed methods of collection.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to
exceed $25,000 whenever it appears to the Court the taxpayer’s
position in such a proceeding is frivolous or groundless. Sec.
6673(a)(1)(B). Respondent has not asked the Court to impose a
penalty under section 6673(a) against petitioner. However, the
Court may, sua sponte, impose this penalty. Pierson v.
Commissioner, 115 T.C. 576, 580 (2000); Rewerts v. Commissioner,
T.C. Memo. 2004-248; Jensen v. Commissioner, T.C. Memo. 2004-120.
Petitioner has previously been a litigant in this Court. In
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