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groundless. The Court warned petitioner that further groundless
arguments would warrant sanctions. Petitioner disregarded the
Court’s warning. The Court will grant respondent’s Motion and we
will require petitioner to pay a penalty of $1,000 pursuant to
section 6673.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order and decision
will be entered.
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Last modified: May 25, 2011