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frivolous arguments and, for that reason alone, deserve to have
section 6673(a)(1) penalties imposed against them.
We are also convinced by petitioners’ conduct that they both
instituted and maintained these proceedings for delay, which is a
separate basis for imposing a section 6673(a)(1) penalty. We
struck all but minimal portions of their 74- and 75-page
petitions. Their discovery requests ran to hundreds of pages,
and we granted respondent’s motions for protective orders with
respect thereto, in part on the ground that we agreed with
respondent that the discovery was intended to burden respondent
unduly, waste his resources, and divert him from trial
preparation. Petitioners actively, indeed, forcefully,
prosecuted these cases until 2 weeks before trial. At that
point, they attempted to withdraw their petitions, asserting a
jurisdictional challenge premised on their disavowal of any
commercial relationship with, and any enjoyment of benefits from,
the United States. They refused to appear for trial or for a
hearing on respondent’s motions to dismiss for default, despite
notice thereof in both instances. We interpret petitioners’
actions in prosecuting (and not prosecuting) these cases as
evidence of their intent to delay these proceedings. There are
numerous years and, for some years, large dollar amounts involved
in these cases. There is before us another case, involving Dr.
Trowbridge and his 1996 and 1997 tax years. That case involves
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