- 37 -
against both the Nis, as individuals, and the Trusts. See supra
note 5. However, petitioner Hae-Rong Ni, as trustee, has not
limited himself to filing protective petitions in the Trust
cases. He has raised the same frivolous arguments with respect
to the Trust that he has raised in his individual capacity. Such
duplication has served to burden respondent and the Court and
delay disposition of these cases. We will, therefore, impose
penalties not only on Hae-Rong (and Lucy B.) Ni but also on the
Trusts. Taking into account the actions of petitioner Hae-Rong
Ni in the Trust cases and petitioners Hae-Rong and Lucy B. Ni in
their case, the amounts in dispute in each case, respondent’s
efforts to dissuade petitioners from their groundless arguments,
and the time and effort of the Court required to dispose of these
cases, we believe that the maximum penalty, in the amount of
$25,000, is appropriate with respect to petitioners Hae-Rong and
Lucy B. Ni, and smaller penalties, in the amount of $500 in the
case at docket No. 9820-99, and $5,000 in the case at docket No.
9821-99, are appropriate with respect to each of the Trusts.
4. Conclusion
The order to show cause shall be made absolute, and
petitioner (petitioners) in each case shall pay to the United
States a penalty pursuant to section 6673(a)(1) in the amount of
$25,000 in docket No. 9822-99, $500 in docket No. 9820-99, and
$5,000 in docket No. 9821-99.
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