James D. and Rita K. Snyder - Page 34




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          respondent was forced to obtain certified copies of these records           
          and offer them separately to the Court.                                     
               Petitioners filed a motion on June 5, 2000, requesting that            
          the notice be declared invalid, which motion the Court denied.              
          On October 2, 2000, petitioners filed another motion requesting             
          that the notice be declared invalid despite the fact that the               
          Court had already considered the issue, which motion the Court              
          again denied.                                                               
               Finally, on brief, petitioners have failed to address the              
          substance of respondent’s objections.                                       
                    5.  Conclusion                                                    
               Petitioners are deserving of a penalty under section                   
          6673(a)(1).  As we stated supra, sec. III.B.1.:  The purpose of             
          section 6673 is to compel taxpayers to think and to conform their           
          conduct to settled principles before they file returns and                  
          litigate.  Petitioners are intelligent people.  They know that,             
          when taken together, their returns and the trust returns                    
          virtually eliminate their liability to pay tax by offsetting,               
          against income that they earned, deductions for personal expenses           
          that they could not have claimed on their own returns.  Rita                
          Snyder is a professional preparer of tax returns and, we assume,            
          has sufficient experience to know that such scheme was                      
          illegitimate.  They failed to cooperate in respondent’s                     
          examination and in preparation of this case for trial.  They have           
          delayed these proceedings.  Because of their stonewalling and               




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