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(2002) (Commissioner not required to identify Code sections
establishing tax liability); Thacker v. United States, 84 AFTR 2d
6303, 99-2 USTC par. 50862 (E.D. Ky. 1999) (assessment not
required for tax liability to exist), affd. 221 F.3d 1336 (6th
Cir. 2000); Residential Mgmt. Servs. Trust v. Commissioner, supra
(trust income attributed to petitioners for 1995); Schaefer v.
Commissioner, T.C. Memo. 1983-361 (assessment not required for
tax liability to exist). We conclude that petitioners’ claims
are frivolous and groundless, see Coleman v. Commissioner, 791
F.2d 68, 71 (7th Cir. 1986), and that they instituted this case
for purposes of delay. Under these circumstances, we require
petitioners to pay to the United States a $5,000 penalty under
section 6673(a).
An appropriate order
and decision will be entered.
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Last modified: May 25, 2011