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Court’s time and resources have been wasted, and we are convinced
that petitioners maintained this proceeding primarily for delay.
In view of the foregoing we shall exercise our discretion
under section 6673(a)(1) and require petitioners David R. and
Darlene Funk (docket No. 18510-99) to pay a penalty to the United
States in the amount of $3,000. We shall also require each
petitioner in docket Nos. 1366-00 through 1371-00 to pay a
penalty to the United States in the amount of $1,000 each.
To reflect the foregoing,
An appropriate order
will be issued.3
3 As previously indicated, the Court will order respondent
to provide a computation in all dockets which reflects consistent
treatment of income in these related dockets.
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Last modified: May 25, 2011