Daniel J. Sides - Page 4

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               Upon the basis of the facts of this case, we shall not now             
          impose a penalty pursuant to section 6673(a)(1).  We take this              
          opportunity, however, to warn petitioner that the Court shall               
          impose such a penalty if he returns to the Court and proceeds in            
          a similar fashion in the future.                                            
               To reflect the foregoing,                                              
                                                  An appropriate order and            
                                             decision will be entered.                

































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