-8-
We agree with respondent that petitioners’ positions in this
proceeding are both groundless and frivolous. Whereas
petitioners alleged in their petition that “assessing taxes that
require that I deny my religious beliefs are unconstitutional,”
petitioners proceeded in brief to abandon that argument and to
put forth only shopworn tax-protester-type gibberish aimed
directly at the validity of our income tax system rather than at
the validity of respondent’s determinations. Petitioners’ sole
arguments in brief are that: (1) ”the tax system is voluntary,”
(2) Mr. Gage “is not a public sector employee,” (3) “the Internal
Revenue Code has not been enacted as positive law,” and (4) ”the
intervener, Gary Gene: Gage, [sic] is the holder in due course of
GARY G. GAGE.”
Because petitioners’ positions are contrary to law and are
not supported by a reasonable argument for a change in the law,
we conclude that their positions are frivolous and groundless.
Accordingly, in the exercise of our discretion, we require them
to pay to the United States a $1,000 penalty under section 6673.
Contentions we have not addressed are irrelevant, moot, or
merit less. To reflect the foregoing,
An appropriate order and
decision will be entered.
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