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the creditors’ meeting in order to levy upon the property to
which those liens attached.
We have considered all of petitioner’s contentions. To the
extent not addressed herein, those contentions are without merit
or unnecessary to reach.
VII. Section 6673.
The record in the instant case shows that respondent warned
petitioner in November 2003, and again in the notice of
determination, that this Court could impose a penalty under
section 6673, and further warned petitioner that his section 861
argument was frivolous and groundless. Section 6673(a)(1)
provides that this Court may require the taxpayer to pay a
penalty not in excess of $25,000 whenever it appears to this
Court that: (a) The proceedings were instituted or maintained by
the taxpayer primarily for delay; (b) the taxpayer’s position is
frivolous or groundless; (c) or the taxpayer unreasonably failed
to pursue available administrative remedies.
Petitioner’s 1996 and 1997 tax returns were nothing but
vehicles to assert his frivolous section 861 argument that he did
not owe taxes. The record also contains several letters from
petitioner to respondent which contain nothing but his frivolous
861 argument and assorted frivolous free speech arguments.
Petitioner was well aware that respondent intended to
collect petitioner’s tax liabilities long before he filed his
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