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instituting or maintaining actions under those sections primarily
for delay or by taking frivolous or groundless positions in such
actions. In the Court’s Order dated March 17, 2003, and at
trial, the Court reminded petitioner about section 6673(a)(1) and
indicated that, in the event that petitioner continued to make
statements, advance contentions and arguments, and/or raise
questions that the Court finds to be frivolous and/or groundless,
the Court would be inclined to impose a penalty under that
section. Nonetheless, petitioner continued to adhere to those
statements, contentions, and arguments.
In the instant case, starting around April 26, 2000, when
petitioner submitted to respondent amended returns for his
taxable years 1995 and 1996, through the trial in this case,
petitioner has advanced, we believe primarily for delay, frivo-
lous and/or groundless contentions, arguments, and requests with
respect to petitioner’s unpaid liabilities for 1995 and 1996,
thereby causing the Court to waste its limited resources in
addressing such matters. As a result of petitioner’s position
and actions in the instant case with respect to petitioner’s
unpaid liabilities for 1995 and 1996, we shall impose a penalty
on petitioner pursuant to section 6673(a)(1) in the amount of
$1,500.
We have considered all of petitioner’s contentions, argu-
ments, and requests that are not discussed herein, and we find
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