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Order dated February 4, 2002, in the case at docket No. 10000-00,
an Order dated January 18, 2002, in the case at docket No. 10001-
00, and an Order dated January 18, 2002, in the case at docket
No. 10002-00 to be frivolous and/or groundless. In each of those
Orders, the Court reminded each petitioner about section
6673(a)(1).8
On February 15, 2002, Herbst Management Trust, Herbst
Charitable Trust, Ms. Herbst, and Mr. Herbst filed a joint brief
in these cases. That brief sets forth statements, contentions,
8Sec. 6673(a)(1) states:
SEC. 6673. SANCTIONS AND COSTS AWARDED BY COURTS.
(a) Tax Court Proceedings.--
(1) Procedures instituted primarily for de-
lay, etc.--Whenever it appears to the Tax Court
that--
(A) proceedings before it have been
instituted or maintained by the taxpayer
primarily for delay,
(B) the taxpayer’s position in such
proceeding is frivolous or groundless, or
(C) the taxpayer unreasonably failed to
pursue available administrative remedies,
the Tax Court, in its decision, may require the
taxpayer to pay to the United States a penalty not
in excess of $25,000.
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