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comply with the Court's Order directing the filing of a proper
second amended petition. Considering all of the circumstances,
we will exercise our discretion under section 6673(a)(1) and
require petitioner to pay a penalty to the United States in the
amount of $2,500. Coleman v. Commissioner, supra at 71-72; Crain
v. Commissioner, supra at 1417-1418; Abrams v. Commissioner,
supra at 408-411.
To reflect the foregoing,
An order and decision will be
entered granting respondent's Motion
for Summary Judgment and imposing a
penalty upon petitioner pursuant to
section 6673(a)(1).
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Last modified: May 25, 2011