5
affirmed the approval by that court of a penalty imposed by
respondent for filing a frivolous return.
Finally, the Court of Appeals imposed double costs and
damages against petitioners for bringing such frivolous appeals.
All this was known to petitioners well in advance of trial
and briefing in the instant case. As though it had never
happened, petitioners went right ahead in the matter before us,
repeating the same stale and discredited protester arguments and
consuming valuable time of the Court, as well as respondent's
counsel, in reading and responding to them.
In the stipulation of facts executed by the parties and
filed at trial herein, and on brief, respondent made certain
concessions as to the amount of deductible expenses incurred by
petitioners, and as to the correct amount of gross income of
petitioners for the years 1990 and 1991, and such concessions
will be given effect under Rule 155 in arriving at the decision
which is to be entered herein.1
As for the rest of it, we see no need to catalog
petitioners' contentions and painstakingly address them. We have
dealt with most of them before. Moreover, as the Court of
Appeals for the Fifth Circuit has remarked: "We perceive no need
to refute these arguments with somber reasoning and copious
1 Respondent made the concessions herein after having
examined petitioners' books and records, which had been made
available to her by petitioners only after the statutory notice
herein was issued.
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