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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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Last modified: May 25, 2011