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We conclude that petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. Petitioner was duly warned that
his arguments were frivolous and groundless, that his case was
not appealable to the Court, and of the potential consequences of
his actions. Accordingly, pursuant to section 6673(a), we hold
petitioner is liable for a $1,000 penalty.
To reflect the foregoing,
An appropriate order and
order of dismissal will be
entered.
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Last modified: May 25, 2011