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Courts which have addressed the precise argument petitioners
make herein have rejected it as frivolous. Takaba v.
Commissioner, 119 T.C. 285, 294-295, 300-302 (2002); Williams v.
Commissioner, supra; Corcoran v. Commissioner, T.C. Memo.
2002-18, affd. 54 Fed. Appx. 254 (9th Cir. 2002); Madge v.
Commissioner, T.C. Memo. 2000-370, affd. 23 Fed. Appx.
604 (8th Cir. 2001); Aiello v. Commissioner, T.C. Memo. 1995-40;
Solomon v. Commissioner, T.C. Memo. 1993-509, affd. without
published opinion 42 F.3d 391 (7th Cir. 1994).
We sustain respondent’s tax lien filing with regard to
petitioners’ 1997 assessed and unpaid 1997 Federal income tax
deficiency, accuracy-related penalty, and interest.
Lastly, we address respondent’s motion for an award of
damages under section 6673. On the basis of the Court’s dialogue
with petitioners, which occurred at the hearing on respondent’s
motion for summary judgment, we decline to impose any
section 6673 penalty on petitioners. We strongly encourage
petitioners to abandon all erroneous arguments such as those made
herein and to bring their conduct into full compliance with the
Federal tax laws.
To reflect the foregoing,
An appropriate Order and
Decision will be entered for
respondent.
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Last modified: May 25, 2011