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and deserve no further attention from this Court.” Howard v.
Commissioner, T.C. Memo. 1998-57.
Petitioner has knowingly and repeatedly advocated frivolous
and groundless positions. His conduct has wasted the time and
resources of this Court. Accordingly, a penalty is awarded to
the United States under section 6673 in the amount of $5,000.
An appropriate order will be issued
granting respondent’s motion for a
penalty, and decision will be entered
under Rule 155.
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Last modified: May 25, 2011