Daniel G. Callahan, et al. - Page 12




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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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