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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 against
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