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without substance.
Under these circumstances, we hold that petitioner’s
position in this proceeding is frivolous and that it has been
interposed primarily to protest the tax laws of this country
and/or to delay collection activity by respondent. Accordingly,
we hold that petitioner is liable for a $4,000 penalty under
section 6673(a)(1).
To reflect the foregoing,
An Order and Decision will be
entered granting respondent’s
motion for summary judgment.
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Last modified: May 25, 2011