- 13 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011