Fatai O. and Mary T. King - Page 3

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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                       
               To reflect the foregoing,                                                

                                                   An appropriate order will            
                                              be issued, and decision will              
                                              be entered under Rule 155.                

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