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and he has persisted. Serious sanctions are necessary to deter
petitioner and others similarly situated; the penalty must be
substantial for it to have a deterrent effect. See Takaba v.
Commissioner, 119 T.C. 285, 295 (2002) (citing Coleman v.
Commissioner, 791 F.2d 68, 71 (7th Cir. 1986)). Pursuant to
section 6673(a)(1), we impose against petitioner a penalty in the
amount of $15,000. See Brenner v. Commissioner, T.C. Memo.
2004-202; Hill v. Commissioner, T.C. Memo. 2003-144.
An appropriate order and
decision will be entered for
respondent.
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