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The Court is also convinced that petitioner instituted and
maintained this proceeding primarily, if not exclusively, for
purposes of delay. Having to deal with this matter wasted the
Court's time, as well as respondent's. Petitioner, likewise,
wasted his own time. In view of the foregoing, this Court grants
respondent's request and exercises its discretion under section
6673(a)(1) by requiring petitioner to pay a penalty to the United
States in the amount of $300. Coleman v. Commissioner, supra at
71-72; Crain v. Commissioner, 737 F.2d 1417, 1418 (5th Cir.
1984); Coulter v. Commissioner, 82 T.C. 580, 584-586 (1984);
Abrams v. Commissioner, 82 T.C. 403, 408-411 (1984).
Decision will be entered
for respondent.
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