Robert H. Deputy - Page 9

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               Under these circumstances we are convinced and hold that               
          petitioner’s position in this proceeding is frivolous and has               
          been interposed primarily to protest the tax laws of this country           
          and/or to delay collection activity by respondent.  We note that            
          petitioner was made aware on several occasions that his arguments           
          were considered frivolous and without merit.  Accordingly, we               
          hold that petitioner is liable for a $2,000 penalty under section           
          6673(a)(1).                                                                 
               To reflect the foregoing,                                              


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






















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