John Robert Forrest - Page 6

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          caused this Court to waste its limited resources on his erroneous           
          interpretations of the Internal Revenue Code which he knew or               
          should have known are completely without merit.  In view of the             
          foregoing, we will exercise our discretion under section 6673(a)            
          and require petitioner to pay a penalty to the United States in             
          the amount of $500.                                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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