- 7 - 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.Page: Previous 1 2 3 4 5 6 7Last modified: November 10, 2007