Citation Codes Equivalent Citations citation codes Docket Number Nos. 84-1745 to 84-1752, 84-2022 to 84-2024. Attorney(S) Rocky N. Unruh, San Francisco, Cal., for plaintiffs-appellants. Elaine F. Ferris, Dept. of Justice, Washington, D.C., for defendant-appellee. Judges Cynthia Holcomb Hall Charles Edward Wiggins Russell Evans Smith Acts Internal Revenue Code — Procedure And Administration — Additions To The Tax, Additional Amounts, And Assessable Penalties — Assessable Penalties — General Provisions — Frivolous Tax Submissions See more information ... Smart Summary Please sign up to generate summary. SHARON FRANKLET, PLAINTIFF-APPELLANT, v. UNITED STATES OF AMERICA, DEFENDANT-APPELLEE. DINAH BACHRACH, PLAINTIFF-APPELLANT, OPINION PER CURIAM: In these eleven cases, which were consolidated for this hearing, the appellants all filed income tax returns making claims for war tax credits or deductions. The Internal Revenue Service penalized the appellants for filing "frivolous" income tax returns ( 26 U.S.C. § 6702) for the year 1982. Appellants challenged the assessments in the District Court for the Northern District of California. Judgments in favor of the United States were entered in all cases. For the reasons stated in the opinion in Franklet v. United States, 578 F. Supp. 1552 (N.D.Cal. 1984), we affirm the judgments. One opinion was written to decide eight of the cases which had been consolidated. Another judge, relying on the opinion in Franklet, entered judgment in the three remaining cases, which also had been consolidated. We note that, since the decision in Franklet, similar results have been reached in Wall v. United States, 756 F.2d 52 (8th Cir. 1985); Kahn v. United States, 753 F.2d 1208 (3d Cir. 1985); and Welch v. United States, 750 F.2d 1101 (1st Cir. 1985). See also Jenney v. United States, 755 F.2d 1384 (9th Cir. 1985).