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proceeding is frivolous and groundless. Accordingly, we shall
grant respondent's motion to dismiss for failure to prosecute and
sustain respondent's determinations as set forth in her notice of
deficiency. We further conclude that petitioner is liable for a
penalty under section 6673 in the amount of $5,000.
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011