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assessment. At that time, the Court admonished petitioner that
he was wasting the Court’s time.
At trial, respondent advised the Court that he had provided
petitioner with a copy of Davis v. Commissioner, 115 T.C. 35
(2000). At the conclusion of the trial, respondent argued that
petitioner was fighting a frivolous battle and that this case was
nothing more than an attempt to further delay the collection
activities. We agree.
In the petition, at trial, and on brief petitioner raised,
primarily for delay, arguments and contentions that we have
previously rejected, thereby causing the Court to waste its
limited resources. Accordingly, we shall impose a penalty of
$10,000 pursuant to section 6673.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011