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or maintaining actions under those sections primarily for delay
or by taking frivolous or groundless positions in such actions.
In the Appeals officer’s January 5, 2004 letter, the Appeals
officer advised petitioner that “the courts have consistently and
repeatedly rejected the arguments expressed in your letters and
in many cases have imposed sanctions.” In that letter, the
Appeals officer also advised petitioner of the holding in Pierson
v. Commissioner, supra, and provided petitioner with a list of
other cases in which a penalty under section 6673(a)(1) had been
imposed. Nonetheless, in the instant case, petitioner alleged in
the petition and advances in petitioner’s response, we believe
primarily for delay, frivolous and/or groundless statements,
contentions, arguments, and requests, thereby causing the Court
to waste its limited resources. We shall impose a penalty on
petitioner pursuant to section 6673(a)(1) in the amount of
$1,000.
We have considered all of petitioner’s statements, conten-
tions, arguments, and requests that are not discussed herein, and
we find them to be without merit and/or irrelevant.10
10We shall, however, address one of petitioner’s contentions
in petitioner’s response. Petitioner contends in petitioner’s
response that the Appeals officer refused “to afford petitioner
the CDP hearing". On the record before us, we disagree. In the
Appeals officer’s February 6, 2004 letter, the Appeals officer
informed petitioner that “If you wish to have a face-to-face
conference, please write me within 15 days from the date of this
letter * * * and describe the legitimate issues you will dis-
(continued...)
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