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genuine controversies were delayed. Under the circumstances
herein, a penalty is warranted under section 6673(a).
In view of the foregoing, we will sua sponte exercise our
discretion under section 6673(a)(1) and require petitioner to pay
a penalty to the United States in the amount of $1,000. Coleman
v. Commissioner, supra at 71-72; Crain v. Commissioner, supra at
1417-1418; Coulter v. Commissioner, 82 T.C. 580, 584-586 (1984);
Abrams v. Commissioner, 82 T.C. 403, 408-411 (1984).
In order to reflect the foregoing,
An order and decision will be
entered granting respondent's motion
to dismiss and imposing a penalty upon
petitioner pursuant to section
6673(a)(1).
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