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respondent points to (1) petitioners’ trial memorandum that the
Court had filed as of September 12, 2000, the date of its receipt
by the Court, (2) the Court’s September 19, 2000 Order directing
that that trial memorandum be filed, (3) petitioners’ motion to
dismiss filed on October 16, 2000, and (4) the Court’s October
19, 2000 Order denying that motion. In the September 19, 2000
Order, we stated that we found the arguments and contentions with
respect to the jurisdiction and authority of the Court that
petitioners advanced in petitioners’ trial memorandum to be
frivolous and/or groundless. We also reminded petitioners in the
September 19, 2000 Order about section 6673(a)(1) and informed
them 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 peti-
tioners under section 6673.” In the October 19, 2000 Order, we
found the contentions of petitioners that the Court lacks juris-
diction over the instant case because the notice issued to
petitioners was not personally signed by the Commissioner of
Internal Revenue to be frivolous and groundless. We further
noted in the October 19, 2000 Order that petitioners were contin-
uing to advance in this case what we found to be frivolous and
groundless contentions, and we cited in that Order our September
19, 2000 Order, in which we indicated that we would be inclined
to impose a penalty under section 6673 in the event that peti-
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