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tion of a penalty under section 6673(a) on those taxpayers who
abuse the protections afforded by sections 6320 and 6330 by
instituting or maintaining actions under those sections primarily
for delay or by taking frivolous or groundless positions in such
actions.7
In the instant case, petitioners advance, we believe primar-
ily for delay, frivolous and/or groundless contentions, argu-
ments, and requests, thereby causing the Court to waste its
limited resources. We shall impose a penalty on petitioners
pursuant to section 6673(a)(1) in the amount of $3,000.
We have considered all of petitioners’ contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and/or irrelevant.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An appropriate order granting
respondent’s motion and decision
will be entered for respondent.
7The record in this case reflects that the settlement offi-
cer gave petitioners, inter alia, a copy of the Court’s opinion
in Pierson v. Commissioner, 115 T.C. 576 (2000).
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Last modified: May 25, 2011