James and Terri Carskadon - Page 9

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               A petition to the Tax Court is frivolous if it is contrary             
          to established law and unsupported by a reasoned, colorable                 
          argument for change in the law.  Coleman v. Commissioner, 791               
          F.2d 68, 71 (7th Cir. 1986).  As set forth in their petition,               
          petitioners have raised only frivolous arguments which can be               
          characterized as tax protester rhetoric.  Based on well-                    
          established precedent, petitioners’ arguments are frivolous and             
          groundless.                                                                 
               Further, the record in this case establishes that                      
          petitioners had no interest in disputing either the deficiency or           
          the penalty determined by respondent.  Petitioners’ failure to              
          file an amended petition in compliance with the Court’s order of            
          March 15, 2000, coupled with their failure to appear at the June            
          5, 2000, hearing, convinces us that these proceedings were                  
          instituted primarily for delay.  Petitioners with genuine                   
          controversies were delayed while we considered this case.                   
               Based on our findings that (1) petitioners’ arguments are              
          frivolous and groundless, and (2) these proceedings were                    
          instituted primarily for delay, we require petitioners to pay a             
          penalty to the United States in the amount of $2,000.  See sec.             
          6673(a)(1); Abrams v. Commissioner, supra at 412-413.                       











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