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and 1997.10
In respondent’s motion, respondent requests that the Court
require petitioner to pay a penalty to the United States pursuant
to section 6673(a)(1). Section 6673(a)(1) authorizes the Court
to require a taxpayer to pay a penalty to the United States in an
amount not to exceed $25,000 whenever it appears that a taxpayer
instituted or maintained a proceeding in the Court primarily for
delay or that a taxpayer’s position in such a proceeding is
frivolous or groundless.
In the Court’s February 22, 2006 Order, the Court, inter
alia, reminded petitioner about section 6673(a)(1) and admonished
him that, in the event he were to advance frivolous and/or
groundless statements, contentions, and arguments in his response
to respondent’s motion, the Court would be inclined to impose a
10The attachment to the notice stated in pertinent part:
I recommend a determination letter be issued to the
taxpayer sustaining the filing of Notice of Federal Tax
Lien. For the years 1980, 1981, * * * tax liability
has been paid.
* * * * * * *
* * * When the Notice of Federal Tax Lien was filed
[with respect to petitioner’s taxable years 1980, 1981,
1982, 1983, 1984, 1992, and 1997] it was appropriate.
The liability was valid and outstanding.
After the notices of Federal tax lien with respect to peti-
tioner’s taxable years 1980 through 1984, 1992, and 1997 were
filed and before the notice of determination was issued, the
unpaid liability for each of his taxable years 1980 and 1981 was
paid.
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