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valuable time and resources to respond to his groundless filings
and other actions, and to conduct a trial at which he failed to
present any evidence whatsoever to prove that respondent’s
deficiency determinations were in error. We will grant
respondent’s motion for sanctions, and we will require petitioner
to pay a penalty to the United States of $2,500.
IV. Conclusion
To reflect the foregoing,
An appropriate order will
be issued, and decision will
be entered under Rule 155.
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