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frivolous and could subject them to penalties under section 6673.
Petitioners were directed to address in their brief the question
of whether a section 6673 penalty should be imposed on them.
They failed to do so, instead persisting in advancing frivolous
tax-protester arguments.
Petitioners’ conduct in this case has wasted the time and
resources of this Court. Their disregard of the Court’s warning
indicates that stronger deterrents are appropriate.
Consequently, the Court will exercise its discretion to impose a
penalty of $1,500 upon each petitioner pursuant to section
6673(a)(1).
To reflect the foregoing,
Appropriate orders and
decisions will be entered under
Rule 155.
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Last modified: November 10, 2007