Rainer B. and Sonja D. Wagner - Page 15

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          misguided views, which we regard as frivolous and groundless.  In           
          short, 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.                                                      
               Under the circumstances, we shall grant that part of                   
          respondent’s motion that moves for the imposition of a penalty in           
          that we shall impose a penalty of $4,000 on petitioners pursuant            
          to section 6673(a)(1).                                                      
               In order to give effect to the foregoing,                              

                                             An appropriate order and                 
                                        decision will be entered.                     

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Last modified: May 25, 2011