Joel L. and Delynn E. Boyce - Page 9

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            colorable argument for change in the law."  Coleman v.                                     
            Commissioner, 791 F.2d 68, 71 (7th Cir. 1986).                                             
                 Petitioners have made frivolous arguments.  They were                                
            advised that the allegations in the petition were similar to                               
            those in other cases for which section 6673 penalties have been                            
            awarded.  Nevertheless, petitioners failed to file an amended                              
            petition containing clear and concise assignments of error or                              
            statements of fact.  Rather, they continued to assert stale and                            
            time-worn tax protester rhetoric.  We find that petitioners have                           
            instituted and maintained this action primarily for delay and                              
            that petitioners' position in this proceeding is frivolous and                             
            groundless.                                                                                
                  In view of the above, respondent's request for a penalty                             
            under section 6673 will be granted, petitioner Joel L. Boyce will                          
            be required to pay the United States a penalty of $10,000, and                             
            petitioner Delynn E. Boyce will be required to pay a penalty of                            
            $5,000.                                                                                    
                                                                  An appropriate order                 
                                                            and decision will be                      
                                                            entered for respondent.                   












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