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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 their
action has resulted in the waste of limited judicial and
administrative resources. Accordingly, respondent's motion is
granted, and we shall require petitioners to pay to the United
States a penalty pursuant to section 6673(a) in the amount of
$1,000.
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