Dean G. Steele - Page 6

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          was attached to respondent's motion.  Nevertheless, petitioner              
          chose to ignore well-established precedent of this and other                
          Federal courts and pursue instead his protest agenda.                       
               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 $1,500.  Coleman v.                   
          Commissioner, supra at 71-72; Crain v. Commissioner, supra at               
          1417-1418; Coulter v. Commissioner, 82 T.C. 580, 584-586 (1984);            
          Abrams v. Commissioner, 82 T.C. 403, 408-411 (1984).                        
               To reflect the foregoing,                                              
                                             An appropriate order and                 
                                        decision will be entered.                     


























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