Daniel and Sally A. Holguin - Page 14

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          actions.14                                                                  
               In the instant case, Mr. Holguin advances, we believe                  
          primarily for delay, frivolous and/or groundless contentions,               
          arguments, and requests, thereby causing the Court to waste its             
          limited resources.  We shall impose a penalty on Mr. Holguin                
          pursuant to section 6673(a)(1) in the amount of $1,600.                     
               We have considered all of petitioners’ contentions, argu-              
          ments, and requests that are not discussed herein, and we find              
          them to be without merit and/or irrelevant.                                 
               On the record before us, we shall grant respondent’s motion            
          for summary judgment as to Mr. Holguin.                                     
               To reflect the foregoing,                                              

                                             An appropriate order granting            
                                        respondent’s motion to dismiss for            
                                        lack of jurisdiction and to strike            
                                        as to petitioner Sally A. Holguin             
                                        will be issued and an order grant-            
                                        ing respondent’s motion for summary           
                                        judgment and to impose a penalty              
                                        under section 6673 as to petitioner           
                                        Daniel Holguin and decision as to             
                                        him will be entered for respondent.           

               14The record in this case reflects that the Appeals officer            
          gave Mr. Holguin “copies of court cases attesting to the fact               
          that the courts are tired of such [frivolous] arguments and could           
          sanction” him.                                                              



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