Alan L. Poe - Page 10

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          by taking frivolous or groundless positions in such actions.  At            
          the Appeals Office hearing, the settlement officer gave                     
          petitioner a copy of Pierson and explained the warning of the               
          Court in that Opinion with respect to section 6673(a)(1).                   
          Nonetheless, in the instant case, petitioner advanced in the                
          petition, we believe primarily for delay, frivolous and/or                  
          groundless statements, contentions, arguments, and requests,                
          thereby causing the Court to waste its limited resources.  We               
          shall impose a penalty on petitioner pursuant to section                    
          6673(a)(1) in the amount of $2,000.                                         
               We have considered all of petitioner’s statements,                     
          contentions, arguments, and requests that are not discussed                 
          herein, and we find them to be without merit and/or irrelevant.             
               On the record before us, we shall grant respondent’s motion.           
          To reflect the foregoing,                                                   

                                             An order granting respondent’s           
                                        motion and an appropriate decision            
                                        will be entered.                              

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