- 9 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011