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there are no genuine issues of material fact and that respondent
is entitled to summary judgment as a matter of law. On the basis
of our review of the record, we find that respondent did not
abuse his discretion in sustaining the tax lien.
Section 6673(a)(1) authorizes the Tax Court to require a
taxpayer to pay to the United States a penalty no greater than
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer’s position in such proceedings is frivolous or
groundless. Although we do not impose a section 6673 penalty on
petitioner today, we strongly warn him that if he advances
similar frivolous arguments in this Court in the future, we may
impose on him a section 6673 penalty up to the $25,000 maximum
allowable amount, even upon our own motion.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011