- 24 - 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.Page: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011