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protester arguments, he presented nothing more than an income tax
return with a zero in each pertinent box. Accordingly,
respondent’s motion for summary judgment will be granted, and
petitioner’s cross-motion for summary judgment will be denied.
Section 6673 Penalty
Respondent has requested that the Court impose a penalty
under section 6673 on the ground that the arguments advanced by
petitioner to respondent and the Court are frivolous. 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,
proceedings have been instituted or maintained by the taxpayer
primarily for delay or that the position of the taxpayer in such
proceeding 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 taxpayers 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
cases premised on arguments akin to those raised herein summarily
and with imposition of the section 6673 penalty. See, e.g.,
Craig v. Commissioner, 119 T.C. 252, 264-265 (2002) (and cases
cited therein).
Petitioner’s arguments in this case are frivolous and
without substance. He has taken numerous unrelated legal
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