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admissions filed January 8, 2002, in respondent’s trial
memorandum, and at the beginning of trial. Petitioner continued
to assert the same arguments during and after trial. We conclude
that petitioner maintained these proceedings primarily for delay
and that her position is frivolous. Under these circumstances,
we require petitioner to pay to the United States a $2,500
penalty under section 6673(a).
Accordingly,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011