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cases. Pierson v. Commissioner, 115 T.C. 576 (2000). Although
we shall not impose a penalty upon petitioners pursuant to
section 6673(a)(1), we admonish petitioners that the Court will
consider imposing such a penalty should they return to the Court
and advance similar arguments in the future.
To reflect the foregoing,
An order granting respondent’s
motion for summary judgment, as
supplemented, and decision will be
entered.
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Last modified: May 25, 2011