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10765-00 and 10766-00 asking the Court to impose a penalty under
section 6673(a)(1) on petitioner in each of those cases, the
Court found in Richards I that petitioner instituted the proceed-
ings in each of those cases primarily for delay and that his
position in each such case was frivolous and/or groundless. We
held in Richards I that petitioner was liable for a penalty under
section 6673(a)(1) in the case at docket No. 10765-00 in the
amount of $8,000 and in the case at docket No. 10766-00 in the
amount of $18,000.
Pursuant to Richards I, on March 28, 2002, the Court entered
an Order of Dismissal and Decision in each of the cases at docket
Nos. 10765-00 and 10766-00. In each such Order, the Court
granted respondent’s motion to dismiss for lack of prosecution in
each such case in that we dismissed each of those cases for
failure by petitioner to prosecute. The Court also entered in
each such Order a decision in each of the cases at docket Nos.
10765-00 and 10766-00 (1) sustaining the determinations that
respondent made in the notice of deficiency to which each such
case pertained, but in reduced amounts which respondent conceded
were appropriate in order to reflect the duplication of certain
income determinations in the respective notices of deficiency
issued to Mr. Richards, and (2) imposing a penalty pursuant to
section 6673(a)(1) on Mr. Richards in the case at docket No.
10765-00 in the amount of $8,000 and in the case at docket No.
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