Emil P. Tolotti, Jr. - Page 15

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          primarily for delay or that the taxpayer's position in such                 
          proceeding is frivolous or groundless.  The Court has indicated             
          its willingness to impose such penalties in collection review               
          cases.  Pierson v. Commissioner, 115 T.C. 576 (2000).  Although             
          we shall not impose a penalty on petitioner pursuant to section             
          6673(a)(1) in the present case, we admonish petitioner that the             
          Court will consider imposing such a penalty should he return to             
          the Court in the future and advance arguments similar to those              
          that we have identified as frivolous.                                       
               To reflect the foregoing,                                              

                                        An order granting respondent’s                
                                   motion for summary judgment, as                    
                                   supplemented, and decision will                    
                                   be entered.                                        

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