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appears to the Court that, inter alia, proceedings have been
instituted or maintained by the taxpayer primarily for delay or
that the taxpayer’s position in such proceeding is frivolous or
groundless. In Pierson v. Commissioner, 115 T.C. at 581, we
warned that taxpayers abusing the protections afforded by
sections 6320 and 6330 through the bringing of dilatory or
frivolous lien or levy actions will face sanctions under section
6673. We have 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 this proceeding primarily for delay.
Throughout the administrative and pretrial process, petitioner
advanced contentions and demands previously and consistently
rejected by this and other courts. He submitted lengthy
communications quoting, citing, using out of context, and
otherwise misapplying portions of the Internal Revenue Code,
regulations, Supreme Court decisions, and other authorities.
While his procedural stance concerning recording was correct, he
ignored the Court’s explicit warning that any further proceedings
would be justified only in the face of relevant and nonfrivolous
issues.
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