John Parks Trowbridge - Page 27

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          conduct similar to that in this case.  See Trowbridge v.                    
          Commissioner, T.C. Memo. 2003-165.  We think that both                      
          petitioners deserve large penalties under section 6673(a)(1).  It           
          is clear to us that Dr. Trowbridge took the lead in the                     
          sanctionable activity here.  Therefore, we shall impose on him a            
          penalty of $25,000.  We shall impose on Ms. Martin, who filed her           
          own petition and submitted documents and took actions that                  
          matched those submitted and taken by Dr. Trowbridge, a penalty of           
          $15,000.                                                                    
               To reflect the foregoing,                                              

                                             Appropriate orders will                  
                                             be issued, and decisions will            
                                             be entered under Rule 155.               

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