-5-
stated that they were provided the opportunity for a hearing and
do not challenge the adequacy of the scheduled hearing. No
further inquiry into the requirements of section 6320(b) is
warranted in this case.
Respondent contends that petitioners’ position is frivolous
and instituted primarily for delay and that, pursuant to section
6673(a)(1), the Court should impose a penalty on petitioners.
We conclude, however, that it is not appropriate to impose such a
penalty in this case.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Appropriate orders and
decisions will be entered.
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Last modified: May 25, 2011