Larry J. and Anita L. Lundgren - Page 23

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          as employing religious doctrine instead of presenting legal                 
          arguments.  The Court is satisfied that a penalty in this case is           
          appropriate, and, therefore, chooses to exercise its discretion             
          sua sponte under section 6673(a)(1) in requiring petitioners to             
          pay a penalty in the amount of $1,500 to the United States for              
          each of these dockets for a total penalty of $3,000.                        
               The Court has considered all of petitioners’ contentions,              
          arguments, requests, and statements.  To the extent not discussed           
          herein, we conclude that they are meritless, irrelevant, or moot.           
               To reflect the foregoing,                                              

                                                  Appropriate decisions               
                                             will be entered.                         

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