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and the instant trial, petitioner stated: “Well, I don’t have
enough information to refute anything at this point.”
We advised petitioner at the 2001 trial that his arguments
were frivolous, and we admonished him against advancing them
again. Our admonition at the 2001 trial was insufficient to
deter petitioner from returning to the Court and advancing the
same frivolous and groundless position in the instant case.
Furthermore, respondent advised petitioner by letter of the
provisions of section 6673, but it also was insufficient to deter
petitioner from returning to the Court and advancing a frivolous
and groundless position in the instant case.
Accordingly, in light of the fact that petitioner took
frivolous or groundless positions in this proceeding and
instituted this proceeding primarily for delay, pursuant to
section 6673(a) we hold petitioner is liable for a $5,000
penalty.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011