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The record indicates that the only issues petitioner raised
throughout the section 6330 administrative process and in his
petition to this Court were frivolous tax protester arguments.
We do not address petitioner’s frivolous arguments with somber
reasoning and copious citations of precedent, as to do so might
suggest that these arguments possess some degree of colorable
merit. See Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir.
1984).
Accordingly, we hold that no genuine issue of material fact
exists requiring trial and that respondent is entitled to summary
judgment. Respondent’s determination to proceed with the
proposed levy to collect petitioner’s tax liability for 1998 was
not an abuse of discretion.
Section 6673(a)(1) authorizes the Court to impose a penalty
not in excess of $25,000 when it appears to the Court that, inter
alia, the proceedings have been instituted or maintained by the
taxpayer primarily for delay or that the position of the taxpayer
in the proceedings is frivolous or groundless. In Pierson v.
Commissioner, 115 T.C. 576, 581 (2000), we issued a warning
concerning the imposition of a penalty under section 6673(a)(1)
on those petitioners abusing the protections afforded by sections
6320 and 6330 through the bringing of dilatory or frivolous lien
or levy actions. The Court has since repeatedly disposed of
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