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conclude that petitioner instituted and maintained this
proceeding primarily for delay.
Accordingly, we hold that petitioner is liable for a $15,000
penalty pursuant to section 6673(a).
In reaching all of our holdings herein, we have considered
all arguments made by the parties, and to the extent not
mentioned above, we find them to be irrelevant or without merit.
To reflect the foregoing,
An appropriate order
and decision will be entered
for respondent.
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Last modified: May 25, 2011