- 86 - tioners continued to advance frivolous and/or groundless conten- tions. According to respondent, after the Court issued the Septem- ber 19, 2000 Order, in which we found the arguments and conten- tions with respect to the Court’s jurisdiction and authority that petitioners advanced in their trial memorandum to be frivolous and/or groundless and in which we reminded petitioners about section 6673(a)(1), petitioners continued to advance contentions in their motion to dismiss filed on October 16, 2000, which the Court found in the October 19, 2000 Order to be frivolous and groundless. Consequently, respondent argues, the Court should impose a penalty on petitioners under section 6673(a)(1). Petitioners do not address the reasons advanced by respon- dent in support of respondent’s position that the Court should impose a penalty under section 6673(a)(1). Instead, petitioners argue that the imposition of such a penalty is not appropriate in the instant case because they refrained from presenting at trial and on brief (1) the same arguments and contentions challenging the Court’s jurisdiction and authority that they had advanced in petitioners’ trial memorandum and (2) “any challenge whatsoever to the Court’s jurisdiction and authority.” On the record before us, we reject petitioners’ position. Petitioners first appear to be taking the position that the September 19, 2000 Order cautioned petitioners only againstPage: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 Next
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