- 19 -
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 trial process, petitioner
advanced contentions and demands previously and consistently
rejected by this and other courts. He submitted communications
quoting, citing, using out of context, and otherwise misapplying
portions of the Internal Revenue Code, regulations, Supreme Court
decisions, and other authorities. He 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, on multiple occasions, expressly
alerted to the potential use of sanctions in his case. Even at
the calendar call the Court specifically warned petitioner about
section 6673. Yet he appeared at the trial 2 days later without
any legitimate evidence or argument in support of his position.
He instead continued to espouse those views that had been
explicitly addressed and rejected in other cases previously
decided by the Court. The Court sua sponte concludes that a
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011