Gerald L. and Jessica P. Frey - Page 40

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          attachment to petitioners’ 1997 Form 1040A.                                 
               On the record before us, we find that petitioners have                 
          advanced, we believe primarily for delay, frivolous and/or                  
          groundless statements, contentions, arguments, requests, and                
          questions with respect to their taxable years 1996, 1997, and               
          1999, thereby causing the Court to waste its limited resources in           
          addressing such matters.  As a result of petitioners’ position              
          and actions in the instant case with respect to those taxable               
          years, we shall impose a penalty on them pursuant to section                
          6673(a)(1) in the amount of $4,000.                                         
               We have considered all of petitioners’ statements,                     
          contentions, arguments, requests, and questions that are not                
          discussed herein, and we find them to be without merit and/or               
          irrelevant.                                                                 
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                                        respondent.                                   

















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