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this case, he persisted in making frivolous and groundless
statements, assertions, contentions, and arguments. On the
instant record, we find that petitioner’s position in this case
is frivolous and groundless and that he instituted and maintained
the instant proceeding primarily for delay. We shall impose on
petitioner pursuant to section 6673(a)(1) a penalty of $1,200.
We have considered all statements, assertions, contentions,
and arguments of petitioner, and, to the extent that they are not
frivolous and/or groundless, we find them to be irrelevant and/or
without merit.
To reflect the foregoing and respondent’s concession,
Decision will be entered under
Rule 155.
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Last modified: May 25, 2011