James Vernon Williams - Page 20

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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            

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Last modified: May 25, 2011