- 34 -                                                  
            educated and, thus, should have been aware that the arguments                              
            that he was making on his own behalf and on behalf of the trusts                           
            are frivolous.  Respondent argues that, had Hae-Rong Ni conducted                          
            any research at all, he would have found that courts have                                  
            rejected similar arguments.  Petitioners have failed to respond                            
            to respondent’s memorandum, and we accept as true respondent’s                             
            representation as to Hae-Rong Ni’s education.  We also agree that                          
            he should have known that his positions were frivolous.                                    
            Consequently, we find that petitioners’ positions in each of                               
            these cases are frivolous.                                                                 
                  Moreover, we believe that petitioners both instituted and                            
            maintained these proceedings primarily for delay.  All of the                              
            petitioners filed returns and reported items of income and                                 
            deduction.  Petitioners Hae-Rong and Lucy B. Ni reported total                             
            taxes due of $2,516.  None of those returns claim that                                     
            petitioners are not subject to the Federal income tax, as                                  
            petitioners claim in the petitions.  The notices of deficiency                             
            are based on the positions taken by petitioners in their returns.                          
            Respondent’s principal adjustment questions the independent tax                            
            existence of the trusts.  Other adjustments disallow deductions                            
            and other amounts for lack of substantiation.  Petitioners have                            
            made no attempt to meet respondent’s adjustments head on.  By the                          
            deemed admissions, petitioners admit the following:  Neither                               
            petitioners Hae-Rong or Lucy B. Ni, in their own right, nor                                
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