Melvin Ray Hassell - Page 17

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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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