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his prior case, petitioner raised many of the same arguments as
in the present case, and those arguments were found to be without
merit. Holliday v. Commissioner, T.C. Memo. 2004-172. In the
present case, the notice of determination warned petitioner that
if he continued to raise frivolous arguments, a penalty could be
imposed. At trial, the Court warned petitioner on three separate
occasions that if he continued to raise only frivolous arguments,
a penalty could be imposed. Despite these warnings, petitioner
continued to assert only frivolous arguments. As a result, we
hold that a penalty of $2,500 against petitioner is awarded to
the United States in this case pursuant to section 6673(a)(1).
In reaching our holdings herein, we have considered all
arguments made, and, to the extent not mentioned above, we find
them to be moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011