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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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