Michael D. Keown and Rosann C. Keown - Page 8

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          no section makes them liable for tax.  The Court finds those                
          contentions to be frivolous and groundless.                                 
               We now turn to the remaining issues that petitioners raised            
          at their Appeals Office hearing and in the petition with respect            
          to petitioners’ notices of determination, which we shall                    
          review for abuse of discretion.  Sego v. Commissioner, supra;               
          Goza v. Commissioner, supra.  We find all those remaining issues            
          to be frivolous and/or groundless.                                          
               Based upon our examination of the entire record before us,             
          we find that respondent did not abuse respondent’s discretion in            
          determining to proceed with the collection action as determined             
          in petitioners’ notices of determination with respect to peti-              
          tioners’ taxable year 1999.                                                 
               In respondent’s motion, respondent requests that the Court             
          require petitioners to pay a penalty to the United States pursu-            
          ant to section 6673(a)(1).  Section 6673(a)(1) authorizes the               
          Court to require a taxpayer to pay to the United States a penalty           
          in an amount not to exceed $25,000 whenever it appears to the               
          Court, inter alia, that a proceeding before it was instituted or            
          maintained primarily for delay, sec. 6673(a)(1)(A), or that the             
          taxpayer’s position in such a proceeding is frivolous or ground-            
          less, sec. 6673(a)(1)(B).                                                   
               In Pierson v. Commissioner, 115 T.C. 576, 581 (2000), we               
          issued an unequivocal warning to taxpayers concerning the imposi-           

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