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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).
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