David White - Page 8

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          imposing a penalty if he returned to the Court and made similar             
          arguments.  Accordingly, pursuant to section 6673, we will impose           
          a penalty on petitioner in the amount of $5,000.                            
               To reflect the foregoing,                                              
                                             An order granting respondent's           
                                        motion for summary judgment and               
                                        penalty and decision will be                  
                                        entered for respondent.                       
































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