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tax determined by respondent with respect to petitioner for 1992
and 1993 are set forth above. During 1992, petitioner received
wages from Sunshine Nursing Homes, Inc., in the amount of $6,726,
from New Hope, Inc., in the amount of $1,142, and from Inland
Nurse Providers, Inc., in the amount $2,810. During 1993,
petitioner received wages from Loganhurst Health Care in the
amount of $7,908. In 1993, petitioner also received unemployment
compensation from the State of Washington in the amount of
$2,278. The fact of these payments and the amounts have been
stipulated by the parties. Petitioner and respondent have
stipulated that if petitioner had filed a tax return for 1992 and
1993, he would be entitled to no more than a standard deduction
based on single filing status for those years. The parties also
have stipulated that in 1992, $71 was withheld from petitioner's
wages by Inland Nurse Providers, Inc., and that petitioner made
no other payments of estimated tax for 1992 and no payments of
estimated tax whatsoever for 1993.
At trial, respondent moved for a penalty under section 6673
against petitioner on the grounds that he had instituted and
maintained the proceedings primarily for delay and that his
positions were frivolous and groundless.
Discussion
Petitioner presented no evidence at trial to refute
respondent's determinations. He stipulated to the amount of his
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