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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.
Also relevant is the fact that petitioners are, or should
be, well aware of the provisions of section 6673. After all, at
the administrative conference on August 21, 2001, the Appeals
officer advised petitioners that they were advancing frivolous
arguments; he provided them with a copy of this Court’s opinion
in Pierson v. Commissioner, 115 T.C. 576 (2000), and he referred
them to this Court’s opinion in Davis v. Commissioner, T.C. Memo.
2001-87 (imposing a penalty in the amount of $4,000).
Under the circumstances, we shall grant respondent’s oral
motion for the imposition of a penalty in that we shall impose a
penalty on petitioners pursuant to section 6673(a)(1) in the
amount of $1,000.
In order to give effect to the foregoing,
An appropriate order granting
respondent's motions and decision
for respondent will be entered.
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Last modified: May 25, 2011