Cedric K. and Madelyn D. Nunn - Page 25




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          Commissioner, 661 F.2d at 72; Coulter v. Commissioner, 82 T.C.              
          580, 584-586 (1984).                                                        
               Petitioners cited the Internal Revenue Code, the                       
          Constitution, and various cases.  We have no doubt that                     
          petitioners were thoroughly familiar with the precedent which               
          uniformly denied validity to their position.  The Court informed            
          petitioners several times of the frivolous and groundless nature            
          of their claims.  In addition, the Court warned petitioners four            
          times that their stale and baseless arguments could subject them            
          to a penalty up to $25,000.  Nevertheless, petitioners chose to             
          ignore well-established precedent of this and other Federal                 
          courts and pursue instead their tax-protester rhetoric.                     
               Previously, on its own motion, this Court has awarded                  
          damages to the United States under section 6673 where the                   
          taxpayer advanced frivolous and groundless contentions similar to           
          those advanced by petitioners.  See Abrams v. Commissioner, 82              
          T.C. 403, 408-413 (1984); Coulter v. Commissioner, supra.                   
               In view of petitioners’ egregious conduct in this case, we             
          will exercise our discretion under section 6673(a)(1) and require           















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