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frivolous or groundless arguments that we commonly encounter in
tax protester cases; however, we fail to comprehend on what basis
petitioner prosecuted this case given her admission that she
actually received the January 6, 1999, notice of deficiency 3
days after it was issued. One might therefore wonder whether
petitioner instituted this case primarily for delay. Under the
circumstances, however, we shall give petitioner the benefit of
the doubt, and we shall not impose a penalty on her pursuant to
section 6673(a)(1).
In order to give effect to the foregoing,
An appropriate order granting
respondent's motion and decision
will be entered.
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