Cedric K. and Madelyn D. Nunn - Page 24




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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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