Clyde E. Owens and Marie W. Owens - Page 17

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          4th Amendment to the U.S. Constitution were violated because                
          someone trashed the offices at the Big O businesses in 1990 and             
          1991 and that respondent seized their bank accounts more than 12            
          times.  Petitioners contend that their 5th Amendment guarantee              
          against double jeopardy was violated because we had the February            
          partial trial and the October trial,3 that their 7th Amendment              
          right to a trial by jury has been violated,4 that their                     
          experiences in this case have been cruel and unusual punishment             
          in violation of the 8th Amendment, and that respondent deprived             
          them of life, liberty, or property in violation of the 14th                 
          Amendment.  Petitioners also make vague allegations that                    
          respondent violated their civil rights and contend that each of             
          them should receive $150,0005 in damages and $91,000 in tax                 
               Petitioners offer no reasons or authority to support these             
          claims.  They have no bona fide basis for their positions.                  
          Petitioners' vague and unsubstantiated allegations do not                   
          persuade us that they are entitled to relief from liability for             

               3 The prohibition against double jeopardy does not apply in            
          civil cases or bar the procedure we followed.  Ianniello v.                 
          Commissioner, 98 T.C. 165, 178-179 (1992).                                  
               4 Tax Court petitioners have no right to a jury trial.                 
          Mathes v. Commissioner, 576 F.2d 70, 71-72 (5th Cir. 1978), affg.           
          T.C. Memo. 1977-220.                                                        
               5 Petitioners do not explain why they claimed more damages             
          on brief than the amount Mr. Owens claimed at trial ($100,000).             

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