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review cases. Roberts v. Commissioner, 118 T.C. 365 (2002);
Pierson v. Commissioner, 115 T.C. 576 (2000). Although we shall
not impose a penalty on petitioner pursuant to section 6673(a)(1)
in the present case, we admonish petitioner that the Court will
consider imposing such a penalty should he return to the Court in
the future and advance similar arguments.
To reflect the foregoing,
An order and decision will
be entered granting respondent’s
motion for summary judgment.
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Last modified: May 25, 2011