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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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