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Circuit, and the Supreme Court of the United States. Despite
warning petitioner at least six times at trial that his arguments
were frivolous and groundless, petitioner persisted in making
those arguments at trial and on brief.
We conclude that petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. Accordingly, pursuant to
section 6673(a) we hold petitioner is liable for a $5,000
penalty.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011