Loy Robert Bost, III - Page 3




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          This argument is frivolous.  See secs. 61, 72, 402(a); see also             
          Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983).                     
               Respondent asks that a penalty be imposed under section                
          6673.  That section provides, inter alia, that if it appears to             
          this Court that “the taxpayer’s position * * * is frivolous or              
          groundless”, the Court may impose a penalty in an amount not in             
          excess of $25,000.  Sec. 6673(a).  This Court cautioned                     
          petitioner at the calendar call and at the trial that the                   
          positions he espoused were frivolous and warned him of the                  
          provisions of section 6673.  Petitioner did not heed these                  
          warnings.  We therefore award a penalty to the United States                
          against petitioner in the amount of $1,500.                                 
                                        An appropriate order and decision             
                                   will be entered.                                   
























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