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persisted in advancing contentions that the Court finds to be
frivolous and/or groundless. In its Order dated January 9, 1998,
denying petitioners’ motion to dismiss this case, the Court
cautioned petitioners that if they “continue to advance frivolous
and/or groundless contentions, the Court will be inclined to
impose a penalty not in excess of $25,000 on petitioners under
section 6673.” Pursuant to section 6673, we will impose a
penalty on petitioners in the amount of $10,000.4
To reflect the foregoing,
An appropriate order
will be issued.
4 In the event that petitioners continue to advance
groundless and/or frivolous contentions and/or maintain this
proceeding primarily for delay, the Court will be inclined to
impose an additional penalty under sec. 6673 up to an aggregate
amount of $25,000.
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Last modified: May 25, 2011