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under Article I of the Constitution. Freytag v. Commissioner,
501 U.S. 868 (1991); Rowlee v. Commissioner, 80 T.C. 1111 (1982);
Burns, Stix Friedman & Co. v. Commissioner, 57 T.C. 392 (1971).
The Tax Court is a court of law which exercises judicial power to
interpret and apply the provisions of the Internal Revenue Code
in disputes between taxpayers and the Commissioner. Freytag v.
Commissioner, supra. Moreover, under section 7443A(b)(4), the
Chief Judge of the Tax Court can assign any Tax Court proceeding
to a special trial judge for hearing and the preparation of
proposed findings of fact and written opinion. Id. The Court
rejects this and other tax protester type arguments raised by
petitioners as being frivolous and without merit.
Petitioners have failed to raise any issue with regard to
the amount of their income or deductions, or the correct amount
of their tax liability, including the additions to tax.
Accordingly, they have not raised any justiciable issues, and
respondent's motion to dismiss will be granted.
Section 6673 authorizes this Court to impose a penalty in
favor of the United States, in an amount not to exceed $25,000,
whenever it appears that the taxpayer's position in a proceeding
is frivolous, groundless, or instituted or maintained primarily
for delay. A petition in the Tax Court is frivolous "if it is
contrary to established law and unsupported by a reasoned,
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