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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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