Gregory R. Brown - Page 9

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          section 6673(a)(2).3  Because no justiciable issues were                    
          presented, the bringing of the case in and of itself is nothing             
          more than a delaying tactic requiring the use of Government and             
          Court resources that could otherwise be applied to hear                     
          legitimate taxpayer concerns.  While no penalty is being imposed            
          in this line of cases, Mr. Jewett is reminded of the consequences           
          if he repeats or persists in similar arguments in the future.               
          See sec. 6673(a)(2); Takaba v. Commissioner, 119 T.C. 285, 296-             
          305 (2002); Edwards v. Commissioner, T.C. Memo. 2003-149.                   
               In reaching our holdings herein, we have considered all                
          arguments made, and to the extent not mentioned above, we                   
          conclude them to be moot, irrelevant, or without merit.                     
               To reflect the foregoing,                                              
                                                       Decision will be               
                                                  entered for respondent.             





               3  Sec. 6673(a)(2) provides, in part, as follows:                      
                         (2) Counsel’s liability for excessive                        
                    costs.--Whenever it appears to the Tax Court that                 
                    any attorney or other person admitted to practice                 
                    before the Tax Court has multiplied the                           
                    proceedings in any case unreasonably and                          
                    vexatiously, the Tax Court may require--                          
                              (A) that such attorney or other person                  
                         pay personally the excess costs, expenses,                   
                         and attorneys’ fees reasonably incurred                      
                         because of such conduct * * *                                




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