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IRS Appeals Office dated September 9, 2004, which informed
petitioner that this Court may require a taxpayer to pay a
penalty to the United States when the taxpayer’s position is
frivolous or groundless, or when the taxpayer institutes or
maintains a proceeding primarily for delay. Also attached were
several letters in which respondent’s settlement officers denied
petitioner’s request for a face-to-face conference. In those
letters, respondent’s settlement officers informed petitioner
that
all of the positions or issues you raised in your CDP
request are items either that:
1. Courts have determined are frivolous or
groundless, or
2. Appeals otherwise does not consider.
These are moral, religious, political,
Constitutional, conscientious, or similar
grounds. * * *
Furthermore, this Court has previously cautioned petitioner
that asserting these frivolous arguments might result in a
penalty pursuant to section 6673(a)(1). On August 13, 2004, this
Court entered an order and decision in docket No. 15591-03L that
respondent could proceed with the collection action for
petitioner’s 1999 taxable year. The Court issued the following
warning to petitioner: “We will not impose a penalty upon
petitioner pursuant to section 6673(a)(1) at this time.
Nevertheless, we take this opportunity to admonish petitioner
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Last modified: May 25, 2011