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under section 6673(a)(1) on Mr. Richards in each of those cases.
As grounds therefor, respondent contends that Mr. Richards
(1) instituted proceedings in the Court primarily for delay,
(2) advanced frivolous and groundless positions in such proceed-
ings, and (3) unreasonably failed to pursue administrative
remedies.
On the record before us, we find that Mr. Richards insti-
tuted the proceedings in the cases at docket Nos. 10765-00 and
10766-00 primarily for delay. We also find on that record that
Mr. Richards’ position in the cases at docket Nos. 10765-00 and
10766-00 is frivolous and/or groundless. On the record before
us, we shall impose a penalty in those cases on Mr. Richards
pursuant to section 6673(a)(1) in the amounts of $8,000 and
$18,000, respectively.
To reflect the foregoing,
An appropriate order of dis-
missal for lack of jurisdiction and
denying respondent’s motion will be
entered in each of the cases at
docket Nos. 10764-00 and 10767-00,
and an appropriate order granting
respondent’s motion and decision
will be entered in each of the
cases at docket Nos. 10765-00 and
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