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Petitioner, we believe, has instituted and maintained this
proceeding primarily for delay. His attention has been directed
to our decision in Davis v. Commissioner, supra, wherein the
Court imposed upon the taxpayer a $4,000 penalty under section
6673, for advancing frivolous and groundless claims. Pursuant to
section 6673, we require petitioner to pay to the United States a
penalty of $7,500.
We have considered all arguments made by the parties and
have found those arguments not discussed herein as irrelevant
and/or without merit. To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011