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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.
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