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prepare this opinion, spending time and effort that would have
been better spent on a good faith controversy requiring
resolution of claims having colorable merit.
We therefore exercise our discretion under section
6673(a)(1)(A) and (B), and impose upon and require petitioner to
pay a penalty of $15,000 to the United States.
To give effect to the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011