Thomasita Taylor - Page 20

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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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Last modified: May 25, 2011