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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 even
through the time of trial, petitioner advanced contentions and
demands previously and consistently rejected by this and other
courts. While her procedural stance concerning recording was
correct, she 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 her case.
Yet she appeared at the trial session in Phoenix without any
legitimate evidence or argument in support of her position. She
instead continued to espouse those positions that had been
rejected in this Court’s order of October 4, 2004, or in other
cases previously decided by the Court.
Hence, petitioner received fair warning but has persisted in
frivolously disputing respondent’s determination. The Court
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