- 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 NextLast modified: May 25, 2011