- 20 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20
Last modified: May 25, 2011