Robert E. and Mary K. Adams - Page 6

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          Court on more than one occasion.2 Petitioners’ insistence on                
          making protester type arguments even after both this Court and              
          the U.S. Court of Appeals for the Ninth Circuit have summarily              
          dismissed them indicates an unwillingness on the part of                    
          petitioners to respect the tax laws of the United States.                   
          Petitioners have had a fair warning that more penalties would be            
          imposed if they continued to make frivolous arguments.                      
          Accordingly, we shall impose a penalty on petitioners pursuant to           
          section 6673 in the amount of $10,000.                                      
               To the extent not herein discussed, we have considered the             
          parties’ other arguments and found them to be meritless.                    
               To reflect the foregoing,                                              
                                                  An appropriate order and            
                                             decision will be entered.                






               2  Petitioners were before this Court regarding their 1998,            
          1999, and 2000 tax years, advancing similar protester arguments.            
          We granted summary judgment for respondent with regard to the tax           
          years at issue and imposed a sec. 6673 penalty in the amount of             
          $1,000.  Petitioners appealed our decision to the Court of                  
          Appeals for the Ninth Circuit, which held that “the action was              
          frivolous and maintained by Mr. and Mrs. Adams primarily for                
          delay.”  Adams v. Commissioner, 127 Fed. Appx. 963 (9th Cir.                
          2005).  The Court of Appeals further imposed sanctions on                   
          petitioners in the amount of $2,000 for filing a frivolous                  
          appeal.  Id.                                                                






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