Robert D. Hill - Page 11

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          otherwise make any legitimate attempt to prove respondent’s                 
          determinations wrong.  Petitioner was warned by respondent before           
          trial, and he was warned by the Court during trial, that his                
          position (or lack thereof) was without merit and could subject              
          him to a penalty of up to $25,000 under section 6673(a).                    
          Notwithstanding the fact that we previously sanctioned petitioner           
          in Hill v. Commissioner, T.C. Memo. 2002-272, for $3,500,                   
          petitioner continues to pursue his frivolous and/or groundless              
          arguments.  Petitioner has disregarded these warnings and has               
          consumed wastefully the time, resources, and effort of the Court.           
          We conclude from the record that petitioner’s positions in this             
          proceeding are frivolous and without merit.  We also conclude               
          from the record that petitioner has instituted and maintained               
          this proceeding primarily for delay.  Pursuant to section                   
          6673(a), we require petitioner to pay to the United States a                
          penalty of $15,000.1                                                        











               1 We note that petitioner has two more cases before the                
          Court (docket Nos. 8690-02 and 14771-02).                                   






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