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despite several warnings from the Court that the arguments were
frivolous and groundless and could subject petitioners to a
penalty. In addition, the Court found that petitioners attempted
to deceive respondent and the Court by creating false documents
and that Mr. Nunn’s overall testimony lacked credibility and
truthfulness.
The record in this case provides ample support to convince
us that petitioners were not interested in disputing the merits
of the substantive issues in the case. We are convinced that
petitioners instituted the present proceeding primarily for
delay. In this regard, it is clear that petitioners considered
this proceeding as nothing but a vehicle to protest the tax laws
of this country and to espouse their own misguided views, which
are frivolous and groundless. In short, having to deal with this
matter wasted the Court's time, as well as respondent’s, and
taxpayers with genuine controversies may have been delayed.
Although the Court can demand a higher degree of
responsibility from a member of the bar, litigants cannot be
treated as free to advance frivolous claims merely because they
appear without counsel. Where pro se litigants are warned that
their claims are frivolous, as petitioners were several times,
and where they are aware of the ample legal authority holding
squarely against them, a penalty is appropriate. See Lonsdale v.
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