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"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).
Petitioners' position, based on stale and meritless
contentions, is manifestly frivolous and groundless, and they
have wasted the time and resources of this Court. Accordingly,
we shall grant respondent's motion, and we shall impose a penalty
of $2,500 pursuant to section 6673.
To reflect the foregoing,
An appropriate order will
be issued, and decision will
be entered under Rule 155.
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Last modified: May 25, 2011