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penalty of $5,000 under section 6673 was imposed upon the
taxpayers.
Similarly, petitioners did not raise any bona fide issues or
collection alternatives. Rather, petitioners presented a
“hodgepodge of unsupported assertions, irrelevant platitudes and
legalistic gibberish” similar to those previously rejected by
this Court. Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir.
1984); see Brodman v. Commissioner, supra; Kish v. Commissioner,
T.C. Memo. 1998-16; Fisher v. Commissioner, T.C. Memo. 1996-277.
“We perceive no need to refute these arguments with somber
reasoning and copious citation of precedent; to do so might
suggest that these arguments have some colorable merit”. Crain
v. Commissioner, supra at 1417. The Court rejects these
boilerplate tax-protester types of arguments as frivolous and
without merit. As a result, we hold that respondent did not
abuse his discretion in determining that collection should
proceed.
In the instant case, petitioners were specifically warned on
two occasions of the likelihood of a penalty under section
6673(a)(1) if they continued with these arguments.3 Despite the
3 Sec. 6673(a)(1) provides:
(1) Procedures instituted primarily for delay, etc.--
Whenever it appears to the Tax Court that--
(A) proceedings before it have been instituted or
(continued...)
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