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adhere to those statements, contentions, and arguments at trial
and after trial, thereby causing the Court to waste its limited
resources in addressing such matters. As a result of peti-
tioner’s position that his net profit for each of the years at
issue from his washing machine repair business and his pension
income for 1997 are not subject to tax, we shall impose a penalty
on petitioner pursuant to section 6673(a)(1) in the amount of
$3,000.
We have considered all of petitioner’s statements, conten-
tions, and arguments that are not discussed herein, and we find
them to be without merit and/or irrelevant.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011