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Court hereby places petitioner on notice that if, in the future,
petitioner institutes or maintains a proceeding in the Court
primarily for delay or takes a position in any such proceeding
that is frivolous or groundless, the Court will be inclined to
impose a penalty on him under section 6673(a)(1).
We have considered all of petitioner’s contentions, argu-
ments, and requests that are not discussed herein, and we find
them to be without merit and irrelevant.
To reflect the foregoing,
An order granting respondent’s
motion and decision will be entered
for respondent.
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Last modified: May 25, 2011