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attempted to conceal, mislead, and prevent the collection of
taxes. See Rowlee v. Commissioner, 80 T.C. 1111, 1123 (1983).
Accordingly, Mr. King is liable, pursuant to section 6663, for
the fraud penalty, but, pursuant to section 6662(b), petitioners
are not liable for an accuracy-related penalty.
Respondent moved for a penalty pursuant to section 6673,
which provides that the Court may impose a penalty not in excess
of $25,000. Petitioners’ position is manifestly frivolous and
groundless, see sec. 6673(a)(1)(B), and they have wasted the
resources of this Court. We also note that this was the second
trial at which petitioners submitted altered documents to this
Court. See King v. Commissioner, T.C. Memo. 1998-69, affd.
without published opinion 182 F.3d 903 (3d Cir. 1999).
Accordingly, the Court will impose a $5,000 penalty.
Contentions not addressed are moot, irrelevant, or
meritless.
To reflect the foregoing,
An appropriate order will
be issued, and decision will
be entered under Rule 155.
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Last modified: May 25, 2011