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petitioner are frivolous and wholly without merit. Moreover, we
rejected petitioner's frivolous arguments when he raised them by
motion to dismiss. Accordingly, petitioner was warned of our
opinion with regard to his arguments. We shall require
petitioner to pay a $1,000 penalty under section 6673(a).
To reflect the foregoing,
An appropriate order imposing
the penalty under section 6673(a)
and decision will be entered for
respondent.
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Last modified: May 25, 2011