- 7 -
those advanced by petitioners. See Abrams v. Commissioner, supra
at 408-413. Although we do not now impose a penalty under
section 6673(a)(1), we caution petitioners that if they continue
to advance such arguments to this Court, they will invite such
penalties in the future.
To reflect the foregoing and a concession by the respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011