Roland Allen Pelletier - Page 8

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             the notice of deficiency.  See Rule 142(a).  Accordingly,                
             we hereby sustain the deficiencies and additions set                     
             forth in the notice of deficiency.  We need not consider                 
             respondent's motion for judgment on the pleadings, and we                
             will deny respondent's motion as moot.                                   
                  In view of the fact that petitioner disregarded the                 
             Court's warning and persisted in presenting at trial the                 
             tax protester arguments advanced in his trial memorandum                 
             that have been rejected by the courts in the past, we                    
             find that petitioner instituted or maintained this case                  
             primarily for delay, and we find that petitioner's position              
             in this case is frivolous.  Accordingly, we will require                 
             petitioner to pay to the United States a penalty in the                  
             amount of $10,000, pursuant to section 6673(a).                          
                  To reflect the foregoing,                                           

                                                An appropriate order                  
                                           and decision will be entered.              

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