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so might suggest that these arguments have some colorable merit.”
Crain v. Commissioner, 737 F.2d 1417, 1417 (5th Cir. 1984).
We conclude petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. Accordingly, pursuant to
section 6673(a) we hold petitioner is liable for a $10,000
penalty.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011