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penalty upheld because taxpayer should have known claim was
frivolous).
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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