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issues for the Court to consider. Petitioners have caused
needless expense and wasted resources, not only for the Court,
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