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District of Columbia or are employed by the [Federal]
government.
We reach the same conclusions with respect to the C.
Shirleys that we reach with respect to the J. Shirleys. Although
the C. Shirleys’ deficiency in tax is less than the J. Shirleys’,
the C. Shirleys’ petition clearly evidences their willfulness in
disregarding settled principles before they decided to litigate.
We, therefore, shall require them to pay a penalty under section
6673(a)(1) of $12,500.
An order of dismissal
for lack of jurisdiction will
be entered in docket No.
17076-99. Appropriate orders
will be issued, and decisions
will be entered under Rule
155 in docket Nos. 10151-99,
10152-99, 10153-99, 17074-99,
and 17075-99.
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