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In addition to questioning the authenticity of respondent’s
documentation, petitioners have interposed protester arguments
which have, on numerous occasions, been rejected by the courts.
In order to support their arguments, petitioners have selectively
picked phrases out of context from statutes and/or rulings. In
so doing, petitioners have chosen to ignore more current or
complete statements of the law. Petitioners have ignored the
rules and regulations and contend that they are not required to
comply with or pay attention to respondent’s letters and
determinations. Petitioners’ arguments are superficial and
without substance.
Under these circumstances we are convinced and hold that
petitioners’ position in this proceeding is frivolous and has
been interposed primarily to protest the tax laws of this country
and/or to delay collection activity by respondent. Accordingly,
we hold that petitioners are liable for a $2,000 penalty under
section 6673(a)(1).
To reflect the foregoing,
An appropriate order and
decision will be entered granting
respondent’s motion for summary
judgment.
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Last modified: May 25, 2011