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exceed $25,000 if petitioner advances frivolous arguments.
Respondent did not request the Court to, and we do not, impose a
section 6673 penalty. Nevertheless, we admonish petitioner that
he may be subject to a section 6673 penalty if he asserts
frivolous or groundless contentions in a subsequent proceeding in
this Court.
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011