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complete dominion." Commissioner v. Glenshaw Glass Co., 348 U.S.
426, 431 (1955).
We have considered petitioners' other arguments and find
them meritless.
For the above reasons, we hold that petitioners had
unreported income during the years in issue in the amounts
determined by respondent in the notices of deficiency, as
modified by the stipulation of facts. We also hold that
petitioners are liable for the additions to tax for failure to
timely file income tax returns under section 6651(a) for each of
the years in issue. Petitioners are also liable for the
additions to tax under section 6654(a) for failure to pay
estimated Federal income tax.
We now turn to respondent's request that a penalty against
petitioners under section 6673(a) be awarded. That section
authorizes the 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
the proceeding is frivolous or groundless. Petitioners have been
to this Court on two previous occasions (involving tax years 1989
and 1990-91), where their arguments were rejected. See Sochia v.
Commissioner, T.C. Memo. 1995-475, affd. without published
opinion 116 F.3d 478 (5th Cir. 1997). On the second occasion we
imposed a $2,000 penalty for each of the 2 years in issue. The
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