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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