Karen and Gary Fujita - Page 6




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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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