- 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