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Respondent requests that the Court impose against
petitioners and their counsel a penalty pursuant to section
6673(a)(1) and (2). In support of this request, respondent
contends that petitioners advanced arguments primarily for the
purpose of delaying entry of decision. In the exercise of our
discretion, we shall not grant respondent's request. To reflect
the foregoing,
An appropriate order
will be issued granting
respondent's motion for entry of
decision, and decision will be
entered accordingly.
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Last modified: May 25, 2011