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failure to cooperate, they have lost the opportunity to claim
costs and deductions that they might have been able to claim and
substantiate. That, however, is a cost they have imposed on
themselves.
Without good reason, petitioners have burdened respondent
and this Court with a case that we believe should not have been
brought. As a penalty for such action, we impose a penalty under
section 6673(a)(1) of $15,000.
An appropriate order and
decision will be entered under
Rule 155.
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