- 27 - underlying tax liability for that year because (1) they received a notice of deficiency for that year and (2) failed to file a petition with the Court with respect to that notice. Nonethe- less, Ms. Latos continues to challenge here the underlying tax liability for her taxable year 1995 in the case at docket No. 5829-06L. With respect to her taxable years 1996, 1997, and 1998 at issue here, in Anderson v. Commissioner, supra, the Court reviewed on a de novo basis the underlying tax liability of Ms. Latos and Mr. Anderson for each of their taxable years 1996 and 1997 and held that their arguments with respect to those liabili- ties were “without substance and constitute nothing more than mere protester type arguments, which are not worthy of further analysis or review.” Nonetheless, Ms. Latos continues to advance here essentially the same arguments with respect to her taxable years 1996, 1997, and 1998 that she and Mr. Anderson advanced in Anderson v. Commissioner, supra, with respect to their taxable years 1996 and 1997.22 We believe that Ms. Latos instituted and maintained each of the instant cases primarily for delay and that her position with respect to each of her taxable years 1995 through 1998 is frivo- lous and/or groundless. Although we shall not impose a penalty under section 6673(a)(1) on Ms. Latos in the instant cases, we 22We found above that Ms. Latos may not challenge the under- lying tax liability for each of her taxable years 1996 and 1997.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: November 10, 2007