Ronald Lee Snyder - Page 16

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          we find that respondent did not abuse respondent’s discretion in            
          determining to proceed with the collection action as determined             
          in the notice of determination and in the decision letter with              
          respect to petitioner’s taxable years 1994, 1996, 1998, and 1999.           
               Although respondent does not ask the Court to impose a                 
          penalty on petitioner under section 6673(a)(1), we now consider             
          sua sponte whether the Court should impose a penalty on peti-               
          tioner under that section.  Section 6673(a)(1) authorizes the               
          Court to require a taxpayer to pay a penalty to the United States           
          in an amount not to exceed $25,000 whenever it appears that a               
          taxpayer instituted or maintained a proceeding in the Court                 
          primarily for delay or that a taxpayer's position in such a                 
          proceeding is frivolous or groundless.                                      
               In an Order dated February 23, 2004, the Court cautioned               
          petitioner that in the event he were to advance in this matter or           
          any future matter arguments that the Court finds to be frivolous            
          and/or without merit, it is likely that the Court would impose a            
          penalty on him under section 6673(a)(1).  Since that time,                  
          petitioner has not advanced any contentions or arguments in this            
          case.  See supra note 1.  Although we shall not impose a penalty            
          under section 6673(a)(1) on petitioner in the instant case, we              
          caution him that he may be subject to such a penalty if in the              
          future he institutes or maintains a proceeding in this Court                
          primarily for delay and/or his position in any such proceeding is           






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