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monetary penalty, petitioner insisted on pursuing such frivolous
and groundless arguments at trial and ignored the Court’s
warnings in drafting his posttrial memoranda. By making the
arguments petitioner has unduly wasted the time and resources of
this Court. See Smith v. Commissioner, T.C. Memo. 2000-290.
Petitioner’s conduct deserves an appropriate sanction.
Accordingly, we shall require petitioner to pay to the United
States a penalty under section 6673(a)(1) of $5,000.
To reflect the foregoing and concessions of the parties,
An appropriate order will
be issued granting
respondent’s motion for
sanctions, and an appropriate
decision will be entered under
Rule 155.
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