Dale Curtis Kinslow - Page 7




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               Although petitioner is not liable for the section 6651(a)(2)           
          addition to tax, his position with respect to the substance of this         
          case is both frivolous and groundless.  His insistence on pursuing          
          his fruitless argument has consumed the time and effort of both             
          this Court and the Commissioner, whose time and effort could                
          otherwise have been devoted to resolving bona fide claims of other          
          taxpayers.  See Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986).             
          Accordingly, pursuant to section 6673, we shall require petitioner          
          to pay a penalty to the United States in the amount of $1,000.              
               To reflect the foregoing,                                              


                                                  An appropriate order and            
                                             decision will be entered.                

























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