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The circumstances in this case may merit the imposition of a
penalty under section 6673; however, we shall not now impose such
a penalty. We take this opportunity to caution petitioners that
we will strongly consider imposing such a penalty if they return
to this Court in the future with similar arguments; i.e., that
Native American Indians are not taxable under the Constitution.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011