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We are also convinced that petitioner instituted and
maintained this proceeding primarily, if not exclusively, for
purposes of delay. Dealing with this matter wasted the Court's
time, respondent's time, and taxpayers with genuine controversies
were delayed.
In view of the foregoing, 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 $5,000. See Fox v.
Commissioner, 969 F.2d 951, 953 (10th Cir. 1992), affg. T.C. Memo
1991-240; Crain v. Commissioner, supra at 1417-1418; Coulter v.
Commissioner, 82 T.C. 580, 584-586 (1984).
An order and decision will be
entered granting respondent's
Motion for Summary Judgment and
requiring petitioner to pay a
penalty pursuant to section
6673(a).
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