The following excerpt is from Northey v. C.I.R., 959 F.2d 241 (9th Cir. 1992):
Under 26 U.S.C. 6673, the tax court "may impose a penalty on a taxpayer ... for bringing an action which is frivolous and groundless." Larsen v. Commissioner, 765 F.2d 939, 941 (9th Cir.1985) (per curiam).
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