David J. Wierdsma - Page 5

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          litigant, generally refrained from urging those arguments in his             
          post-trial memorandum.  Moreover, respondent has conceded error              
          in the notice of deficiency with respect to the employment tax               
          determinations.  Therefore, we decline to impose a penalty in                
          this case, and respondent's oral motion will be denied.  In so               
          doing, we caution petitioner that future assertions of such                  
          groundless arguments will result in substantial penalties                    
          pursuant to section 6673.                                                    
               To reflect respondent's concessions,                                    
                                                   An appropriate order                
                                              and decision will be entered.            



























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