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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
6673.
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