Timothy Nicholls - Page 16

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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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