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copious citation of precedent; to do so might suggest that these
arguments have some colorable merit.” Crain v. Commissioner, 737
F.2d 1417, 1417 (5th Cir. 1984).
Petitioners have failed to make a valid challenge to the
appropriateness of respondent’s intended collection action, offer
alternative means of collection, or offer any spousal defenses.
These issues are now deemed conceded. Rule 331(b)(4).
Accordingly, we conclude that respondent did not abuse his
discretion, and we sustain respondent’s determination to proceed
with collection for 1997 and 1998.
II. Section 6673(a)
Section 6673(a)(1) authorizes this Court to require a
taxpayer to pay to the United States a penalty not to exceed
$25,000 if the taxpayer took frivolous positions in the
proceedings or instituted the proceedings primarily for delay. A
position maintained by the taxpayer is “frivolous” if it is
“contrary to established law and unsupported by a reasoned,
colorable argument for change in the law.” Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986).
In his correspondence with petitioners, the settlement
officer advised petitioners to read an IRS publication entitled
“The Truth About Frivolous Tax Arguments”, which explains the
defects in several of petitioners’ arguments. The settlement
officer also sent petitioners a copy of Pierson v. Commissioner,
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