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of the trial, petitioner reneged on the settlement and dismissed
Mr. Thomas. Petitioner then filed a motion to “withdraw” his
petition without prejudice that was without any basis in law or
fact. Finally, on the date of trial, petitioner refused to
appear even though he had been informed that he must appear.
A review of the record satisfies us that petitioner has
maintained this case primarily for delay. The Court’s time and
resources have been wasted. In view of the foregoing, we shall
exercise our discretion under section 6673(a)(1) and require
petitioner to pay a penalty to the United States of $2,000. See
Funk v. Commissioner, T.C. Memo. 2000-169.
To reflect the concessions of the parties,
An appropriate order will
be issued, and decision will be
entered under Rule 155.
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Last modified: May 25, 2011