John Parks Trowbridge - Page 26

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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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