-10-
supra; Pierson v. Commissioner, 115 T.C. 576 (2000); Hoffman v.
Commissioner, T.C. Memo. 2000-198. Moreover, we have imposed
penalties when the underlying tax liability was not at issue and
the taxpayer raised frivolous and groundless arguments as to the
legality of the Federal tax laws. Yacksyzn v. Commissioner,
supra; Watson v. Commissioner, T.C. Memo. 2001-213; Davis v.
Commissioner, T.C. Memo. 2001-87. We do the same here.
Petitioners’ arguments in this Court are mainly groundless and
frivolous, and it appears to us that petitioners instituted and
maintained this proceeding primarily for delay.2 Pursuant to
section 6673, we require petitioners to pay to the United States
a penalty of $2,000.
We have considered all arguments made by the parties and
have found those arguments not discussed herein to be irrelevant
and/or without merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
2 At and after the Appeals Office hearing, petitioners were
made aware of our opinions in Pierson v. Commissioner, 115 T.C.
576 (2000), and Davis v. Commissioner, 115 T.C. 35 (2000). In
Pierson, taxpayers advancing frivolous and groundless claims and
instituting the underlying proceedings for the purposes of delay
were warned that the Court would impose penalties. This warning
went unheeded by petitioners.
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