- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011