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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 lien to collect petitioner’s tax liabilities for 1998,
2000, 2001, and 2002 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, 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. at 264-265 (and cases cited
therein).
Respondent has moved for the imposition of a section 6673
penalty in the instant case. Petitioner has raised only
frivolous arguments, both before and after being warned about
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