Theldon and Mary Parrett - Page 10

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          petitioners referred all correspondence to Mr. Beltran, who had             
          promised to "take care" of the problem, which he failed to do.              
          On this record, the Court sustains respondent on the section                
          6662(a) accuracy-related penalties for the 2 years at issue.                
               Section 6673(a) authorizes the Court to require a taxpayer             
          to pay to the United States a penalty not exceeding $25,000 when,           
          in the Court's judgment, proceedings have been instituted or                
          maintained by the taxpayer primarily for delay or where the                 
          taxpayer's position in the proceeding is frivolous or groundless.           
          The Court considers petitioners' claim that they should not be              
          liable for the deficiencies and penalties to be frivolous and               
          groundless.  Petitioners knew, or should have known, that a                 
          substantial portion of the itemized deductions at issue was false           
          and could not be sustained.  Other circumstances noted above need           
          not be repeated here.                                                       
               The function of this Court is to provide a forum to decide             
          issues relating to liability for Federal taxes.  Any reasonable             
          and prudent person, under the facts presented to the Court,                 
          should have known that the claimed deductions could not have been           
          sustained, and the Court is satisfied that petitioners knew that.           
          We do not and should not countenance the use of this Court as a             
          vehicle for a disgruntled litigant to proclaim the wrongdoing of            
          another, his return preparer, as a basis for relief from a                  
          penalty that was determined by respondent on facts that clearly             

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