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but for its personnel, respondent, and respondent's counsel.
Under these circumstances, the penalty under section 6673 is
warranted, and petitioners will be ordered to pay a penalty of
$500 to the United States under section 6673(a).
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011