Bradley W. Bean - Page 12

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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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