Robert Lee Jr. - Page 14




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                              (A) proceedings before it have been                     
                         instituted or maintained by the taxpayer                     
                         primarily for delay,                                         
                              (B) the taxpayer’s position in such                     
                         proceeding is frivolous or groundless, or                    
                              (C) the taxpayer unreasonably failed to                 
                         pursue available administrative remedies,                    
                    the Tax Court, in its decision, may require the                   
                    taxpayer to pay to the United States a penalty not                
                    in excess of $25,000.                                             
               The various arguments that petitioner made in this case have           
          been long discredited and patently were asserted for purposes of            
          delay.  His inconsistent pleadings show disregard for                       
          truthfulness and for the seriousness of these proceedings.  We              
          conclude that a penalty under section 6673(a) should be awarded             
          to the United States in the amount of $10,000.                              
               To reflect the foregoing,                                              
                                             An appropriate order                     
                                             and decision will be entered.            




















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