Tony Malfatti - Page 9

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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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