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advance the same frivolous arguments with the Court after
repeated warnings. Accordingly, we hold that petitioner is
liable for a $25,000 penalty under section 6673.
We have considered all arguments and have found those
arguments not discussed herein to be irrelevant and/or without
merit. To reflect the foregoing,
An appropriate order and
decision will be entered
for respondent.
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Last modified: May 25, 2011