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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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