- 17 -
and/or his position in any such proceeding is frivolous or
groundless. See Abrams v. Commissioner, 82 T.C. 403, 409-413
(1984); White v. Commissioner, 72 T.C. 1126, 1135-1136 (1979).
We have considered all of the contentions, arguments, and
requests of petitioner that are not discussed herein, and we find
them to be without merit and/or irrelevant.
To reflect the foregoing,
An order denying respondent’s
motion for penalty under section
6673 and decision for respondent
will be entered.
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