- 88 - October 16, 2000. We agree that the reasons presented by respon- dent warrant imposition in the instant case of a penalty under section 6673(a)(1). By continuing to assert after the Court issued the September 19, 2000 Order frivolous and groundless contentions in the motion to dismiss that petitioners filed on October 16, 2000, petition- ers consumed the time and effort of the Court, which otherwise could have been devoted to resolving bona fide claims of other taxpayers. See Coleman v. Commissioner, supra at 72; Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986), affd. per curiam. Based on our examination of the entire record before us, we find that, pursuant to section 6673(a)(1)(B), the imposition of a penalty in the amount of $2,000 is appropriate in this case. We have considered all of the contentions and arguments of petitioners that are not discussed herein, and we find them to be without merit and/or irrelevant. To reflect the foregoing, An approriate order will be issued and a decision will be entered sustaining respondent’s determinations and imposing a penalty under section 6673(a)(1).Page: Previous 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88
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