Edward P. Heaphy - Page 12

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               We have no doubt that petitioner, an educated individual,              
          maintained this proceeding primarily to delay the day the IRS               
          could collect taxes he owes for 1997.  Petitioner has wasted the            
          time of respondent’s representatives, as well as the time of this           
          Court.  We therefore impose a penalty of $3,000 on petitioner               
          under section 6673.                                                         
               We have considered all the arguments and contentions made by           
          petitioner, and to the extent not discussed herein, we conclude             
          they are without merit and/or irrelevant.                                   
               To reflect the foregoing,                                              

                                             Decision will be entered for             
                                        respondent.                                   

























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