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before Appeals, the officer provided petitioner with a copy of
Davis v. Commissioner, supra, and Thompson v. IRS, 57 AFTR 2d 86-
1450, 86-1 USTC par. 9420 (E.D. Cal. 1986), and explained how
those cases reflected a rejection of positions similar to
petitioner’s. Hence, petitioner received fair warning but has
persisted in disputing respondent’s determination. The Court
concludes that a penalty of $2,000 should be awarded to the
United States in this case. We will grant respondent’s motion.
To reflect the foregoing,
An appropriate order
granting respondent’s motion
and decision for respondent
will be entered.
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Last modified: May 25, 2011