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time and resources of the Court. We are convinced that
petitioner instituted and maintained these proceedings primarily
for delay. Accordingly, we shall impose a penalty of $5,000
pursuant to section 6673.
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not
mentioned above, we find them to be irrelevant or without merit.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011