Richard John Florance, Jr. - Page 9

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          (9th Cir. 1988), affg. T.C. Memo. 1987-225; Carter v.                       
          Commissioner, 784 F.2d 1006, 1009 (9th Cir. 1986).  We will not             
          painstakingly address petitioner’s assertions “with somber                  
          reasoning and copious citation of precedent; to do 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 $12,500                  
          penalty.                                                                    
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                





















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