Theldon and Mary Parrett - Page 11

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          are not sustainable.  Golub v. Commissioner, T.C. Memo. 1999-288.           
          Petitioners, therefore, have interfered with the Court's function           
          to the detriment of other parties having cases with legitimate              
          issues for the Court to consider.  Petitioners have caused                  
          needless expense and wasted resources, not only for the Court,              
          but for its personnel, respondent, and respondent's counsel.                
          Under these circumstances, the penalty under section 6673 is                
          warranted, and petitioners will be ordered to pay a penalty of              
          $500 to the United States under section 6673(a).                            
               Reviewed and adopted as the report of the Small Tax Case               

                                             Decision will be entered                 
                                        under Rule 155.                               

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