- 65 - groundless. We reminded petitioners in the September 19, 2000 Order about the provisions of section 6673(a)(1)(A) and (B), which allows the Court to require a taxpayer to pay a penalty to the United States whenever it appears to the Court that a pro- ceeding before it has been instituted or maintained by the taxpayer primarily for delay or when the taxpayer’s position in such a proceeding is frivolous or groundless. We informed petitioners in the September 19, 2000 Order that “In the event that petitioners continue to advance frivolous and/or groundless contentions, the Court will be inclined to impose a penalty not in excess of $25,000 on petitioners under section 6673.” On October 2, 2000, petitioners filed a motion for clarifi- cation of the September 19, 2000 Order (petitioners’ motion for clarification). In that motion, petitioners reasserted their arguments and contentions challenging the Court’s jurisdiction and authority, which we had found in the September 19, 2000 Order to be frivolous and/or groundless.33 On October 2, 2000, we denied petitioners’ motion for clarification. 33In petitioners’ motion for clarification, petitioners stated, inter alia: The Court has not provided any assistance to petition- ers which would enable them to evaluate whether or not to pursue their issue(s), and petitioners seek guidance from the Court. * * * the [September 19, 2000] Order was issued sua sponte, and petitioners have been pro- vided no authority to examine which would explain why their position(s) is/are “frivolous and/or groundless.”Page: Previous 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 Next
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