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reasoning and copious citation of precedent; to do so might
suggest that these arguments have some colorable merit.” Crain
v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984); see
Holliday v. Commissioner, T.C. Memo. 2005-240; Duffield v.
Commissioner, T.C. Memo. 2002-53; Kuglin v. Commissioner, T.C.
Memo. 2002-51.
Petitioner has not presented any evidence or arguments to
convince us that respondent abused his discretion. As a result,
we hold respondent’s determination was not an abuse of
discretion, and respondent may proceed with the proposed
collection action.
Section 6673(a)(1) authorizes the Court to require a
taxpayer to pay the United States a penalty in an amount not to
exceed $25,000 whenever it appears to the Court the taxpayer’s
position is frivolous or groundless. Sec. 6673(a)(1)(B).
Respondent has asked the Court to impose a penalty against
petitioner under section 6673(a).
There is no evidence that petitioner has previously been a
litigant in this Court. However, the Court warned petitioner
that if he continued to raise only frivolous arguments, a penalty
could be imposed. Despite the warning, petitioner continued to
assert only frivolous arguments. As a result, we hold that a
penalty of $1,500 against petitioner is awarded to the United
States pursuant to section 6673(a)(1).
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