- 9 - 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 aboutPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007