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faith. Accordingly, we hold petitioners are liable for the
accuracy-related penalty.
The Court hereby puts petitioners on notice that in any
future proceedings instituted by them primarily for delay, or
where their position in such proceeding is frivolous or
groundless, they will be subject to a penalty not in excess of
$25,000 pursuant to section 6673.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011