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Section 6673 Penalty
We turn now to that part of respondent's motion that moves
for an award of a penalty against petitioners under section
6673(a). Section 6673(a)(1) authorizes the Tax Court to require
a taxpayer to pay to the United States a penalty not in excess of
$25,000 whenever it appears that proceedings have been instituted
or maintained by the taxpayer primarily for delay or that the
taxpayer's position in such proceedings is frivolous or
groundless.
A petition to the Tax Court is frivolous "if it is contrary
to established law and unsupported by a reasoned, colorable
argument for change in the law." Coleman v. Commissioner, 791
F.2d 68, 71 (7th Cir. 1986), affg. an unreported order of this
Court. Based on well-established law, petitioners' positions are
frivolous and groundless.
The record in this case convinces us that petitioners were
not interested in disputing the merits of either the deficiencies
in income tax or the additions to tax determined by respondent in
the respective notices of deficiency. Rather, the record
demonstrates that petitioners regard this case as a vehicle to
espouse their own misguided views of the tax laws of this
country.
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