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The parties stipulated that petitioner has been provided
with a copy of an IRS Notice which outlines common frivolous
arguments and has been advised by respondent that the Court may
require a taxpayer to pay a penalty up to $25,000 pursuant to
section 6673 if it appears to the Court that proceedings have
been instituted or maintained by the taxpayer primarily for delay
or that the taxpayer’s position is frivolous or groundless.
In our November 3, 2004, Order, we gave petitioner the
opportunity to present proper issues, as specified in section
6330(c)(2), during his section 6330 hearing. We warned
petitioner, however, that if he persisted in making frivolous and
groundless arguments, with respect to this case, the Court would
be in a position to impose a penalty under section 6673(a)(1).
Petitioner ignored the Court’s warning and simply pursued his
arguments, which the Court has held to be frivolous, groundless,
and meritless in numerous cases. Under the circumstances, we
shall grant respondent’s motion and impose a penalty on
petitioner pursuant to section 6673(a)(1) in the amount of
$10,000.
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