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those returns the wage income or interest income received during
1993 or 1994.
Petitioners had a prior case before this Court, docket No.
15738-96, involving their tax liability for 1992. In Liddane v.
Commissioner, T.C. Memo. 1998-259, filed July 14, 1998, the Court
rejected petitioners' frivolous arguments that they were not
liable for Federal income tax and imposed a penalty of $2,500
under section 6673.
These cases were submitted on February 1, 1999, and
respondent moved for a penalty under section 6673 in the amount
of $10,000, citing petitioners' prior case and pointing out that
petitioners are raising and asserting here the same frivolous
arguments for nonpayment of taxes that were rejected in the prior
case. Nonetheless, petitioners filed a brief in which they
reasserted the same partially incomprehensible but thoroughly
frivolous arguments that they are not liable for Federal income
taxes on the income that petitioners received in 1993, 1994, and
1995. They argue that income taxes are voluntary, that wages are
not taxable, and that the statutory notices are invalid for
failure to cite legal authority imposing income taxes on
petitioners.
Petitioners' various arguments were addressed in T.C. Memo.
1998-259, and there is no reason to repeat that analysis here.
Petitioners have stipulated the amounts of their interest income
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