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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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Last modified: May 25, 2011