Philip Lewis Hart - Page 8

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          groundless.  Sec. 6673.  Based on the record, we conclude that              
          such an award is appropriate in this case.                                  
               Petitioner has pursued a frivolous and groundless position             
          throughout this proceeding.  At the beginning of this trial,                
          petitioner was clearly warned that if he proceeded with the                 
          arguments contained in his written submission, then he would be             
          subject to penalties.  Petitioner knew or should have known that            
          his position was groundless and frivolous, yet he persisted in              
          maintaining this proceeding primarily to impede the proper                  
          workings of our judicial system and to delay the payment of his             
          Federal income tax liabilities.  Accordingly, a penalty is                  
          awarded to the United States under section 6673 in the amount of            
          $10,000 in each docket.                                                     
               To the extent we have not addressed petitioner's arguments,            
          we have considered them and find them to be without merit.                  

                                             Decision will be entered under           
                                        Rule 155 in docket No. 10398-98               
                                        and decision will be entered for              
                                        respondent in docket No. 16155-98,            
                                        and a penalty will be awarded to              
                                        the United States under section               

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