Cynthia Ann Schlosser - Page 7

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          citation of precedent; to do so might suggest that these                    
          arguments have some colorable merit.”  Crain v. Commissioner, 737           
          F.2d 1417 (5th Cir. 1984).                                                  
               On the basis of our review of the record, we conclude that             
          there is no genuine issue as to a material fact.  In the absence            
          of a valid issue for review, we conclude that respondent is                 
          entitled to judgment as a matter of law and sustain respondent’s            
          collection actions.                                                         
               Section 6673(a)(1) authorizes this Court to require a                  
          taxpayer to pay to the United States a penalty not to exceed                
          $25,000 if the proceedings have been instituted or maintained by            
          the taxpayer primarily for delay or the taxpayer’s position is              
          frivolous and groundless.  Petitioner’s position is frivolous and           
          groundless and has caused this Court to waste limited resources.            
          Accordingly, we hold that petitioner is liable for a $1,000                 
          penalty pursuant to section 6673(a).                                        
               To reflect the foregoing,                                              

                                                   An appropriate order and           
                                             decision will be entered.                

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