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for its collection can be begun or, if a petition is filed, until
a decision of this Court is final. See sec. 6213(a).
Because the petitions fail to state a claim upon which
relief can be granted, we shall grant respondent's motion to
dismiss in each docket. See Rules 34(a)(1), 123(b); Scherping v.
Commissioner, 747 F.2d 478 (8th Cir. 1984).
Section 6673
We now consider that part of respondent’s motions that seeks
an award of a penalty against petitioners under section 6673(a).
Section 6673(a)(1) authorizes the Tax Court to require a taxpayer
to pay to the United States a penalty not in excess of $25,000
whenever it appears that proceedings have been instituted or
maintained by the taxpayer primarily for delay or that the
taxpayer’s position in such proceedings is frivolous or
groundless.
A petition is frivolous if it is contrary to established
law, or unsupported by a reasoned, colorable argument for change
in the law. See Coleman v. Commissioner, 791 F.2d 68, 71 (7th
Cir. 1986), affg. an order of this Court.
A review of the record in these cases satisfies us that
petitioners are not interested in disputing the merits of the
deficiencies, additions to tax, or penalties. Petitioners appear
to regard these cases as a vehicle to present their views. The
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