Robert and Ines M. Gillespie, et al. - Page 15




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          primarily to delay the collection of their income tax liability,            
          (2) in support of that goal, raised frivolous arguments and                 
          relied on groundless claims, and (3) unreasonably failed to                 
          pursue their opportunity for a section 6330 hearing.  We                    
          cataloged our concerns with respect to petitioners generally as             
          follows:  They had not challenged respondent’s statements in                
          support of the motion for summary judgment that petitioners                 
          received a notice of deficiency and failed to petition the Tax              
          Court; they had failed to present the settlement officer any                
          collection alternatives or the financial information necessary to           
          consider collection alternatives; and, in the amended petition,             
          they had made claims that had little or no substance, all but one           
          of which (in docket No. 3405-05L) we had rejected.  We also noted           
          the similarity of the amended petitions to petitions filed by               
          counsel in other cases calendared for trial at the Las Vegas                
          trial session and the shortness of the period between filing                
          those amended petitions and the start of the trial session.  We             
          expressed our skepticism with respect to the “cycle post date”              
          argument made in support of the statute of limitations defense in           
          docket No. 3405-05L, stating our suspicion, based on the                    
          rejection of the same or a similar argument in Dahmer v. United             
          States, 90 AFTR 2d 2002-6804, 2002-2 USTC par. 50,806 (W.D. Mo.             
          2002) (Magistrate Judge’s order), that the argument was                     
          frivolous.  In docket Nos. 3489-05L and 3490-05L, the cases in              







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