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circumstances, we shall, on our own motion, impose a penalty on
petitioner pursuant to section 6673(a)(1) in the amount of
$5,000.
We shall not impose a penalty on Mr. Jewett because of his
late entry into this case, but direct him to review the Court’s
comments in Brodman v. Commissioner, T.C. Memo. 2003-230, and its
companion cases.3
We have considered all of petitioner’s contentions,
arguments, and requests that are not discussed herein, and we
conclude that they are without merit or irrelevant.
To reflect the foregoing,
An appropriate order
and decision will be
entered.
3 Dunham v. Commissioner, T.C. Memo. 2003-260; Brown v.
Commissioner, T.C. Memo. 2003-261.
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