- 23 -
groundless. In Pierson v. Commissioner, 115 T.C. 576, 581
(2000), the Court 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. The Court has 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, we are convinced that
petitioner instituted and maintained this proceeding primarily
for delay. Throughout the administrative process and in his
petition, petitioner advanced contentions and demands previously
and consistently rejected by this and other courts. While his
procedural stance concerning recording was correct and his
contentions regarding nonreceipt of the notices of deficiency
initially gave us pause, his testimony and that of his wife
revealed that these matters in petitioner’s circumstances posed
no legitimate basis for contesting the collection determination.
Hence, petitioner 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
expressly alerted to the potential use of sanctions in his case.
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011