John E. Hunter, II and Alma E. Hunter - Page 20

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               On the basis of our review of the record, we conclude that             
          respondent satisfied the requirements of section 6330(c) and did            
          not err or abuse his discretion in sustaining the notice of                 
          Federal tax lien filing or the proposed levy action against                 
          Mr. Hunter.  Respondent’s determination therefore is sustained.             
          4.  Section 6673                                                            
               In the recommended findings of fact and conclusions of law,            
          Chief Special Trial Judge Panuthos cautioned petitioner about               
          section 6673.  We repeat that warning here.  Section 6673(a)(1)             
          provides for a penalty not in excess of $25,000 if (A)                      
          proceedings in this Court have been instituted or maintained by             
          the taxpayer primarily for delay or (B) the taxpayer’s position             
          is frivolous or groundless.  Mr. Hunter’s arguments have been               
          irrelevant, incoherent, unintelligible, and totally lacking in              
          merit.  If he appears before this Court in the future and makes             
          similar groundless arguments, a penalty pursuant to section                 
          6673(a) may be imposed.                                                     
               In reaching our holding, we have considered all arguments              
          made, and, to the extent not mentioned, we conclude that they are           
          moot, irrelevant, or without merit.                                         
               To reflect the foregoing,                                              

                                                  Decisions will be entered           
                                             for respondent.                          

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