Aaron T. and Linda K. Ball - Page 9

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          penalty upheld because taxpayer should have known claim was                 
               Furthermore, we have warned these petitioners of the                   
          possible consequences of advancing frivolous arguments in this              
          Court.  In a previous appearance before this Court, petitioners             
          made similar frivolous tax-protester arguments.  They were warned           
          that if they brought the arguments to this Court again, a penalty           
          would be imposed.4                                                          
               In the petition and at trial, petitioners raised frivolous             
          arguments and contentions that we have previously rejected and              
          which we conclude were interposed primarily for delay.  This has            
          caused the Court to waste limited resources.  Accordingly, we               
          shall impose a penalty of $5,000 pursuant to section 6673.                  
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered.                     

               4  Petitioners were previously before this court making the            
          same frivolous arguments regarding their 1998 income tax                    
          liability.  Ball v. Commissioner, docket No. 1066-04L.                      

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