- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
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