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legalistic gibberish. Based on well established law,
petitioners' position is frivolous and groundless.
We are also convinced that petitioners instituted and
maintained this proceeding primarily, if not exclusively, for
purposes of delay. Having to deal with this matter wasted the
Court's time, as well as respondent's. Moreover, taxpayers with
genuine controversies were delayed.
In view of the foregoing, we will exercise our discretion
under section 6673(a)(1) and in our decision in docket No.
8625-95 require each petitioner to pay a penalty to the United
States in the amount of $1,500. Coleman v. Commissioner, supra
at 71-72; Crain v. Commissioner, supra at 1417-1418; Coulter v.
Commissioner, 82 T.C. 580, 584-586 (1984); Abrams v.
Commissioner, supra at 408-411.
To reflect the foregoing,
Orders of dismissal and
decisions will be entered in
each case.
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Last modified: May 25, 2011