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could proceed with the collection of petitioner’s tax liabilities
for 2000, 2001, and 2002, and we imposed a $5,000 penalty
pursuant to section 6673(a)(1).
We find that petitioner has asserted frivolous and
groundless arguments in this proceeding which are similar to
those advanced in his prior case before this Court. We also find
that petitioner instituted this proceeding primarily for delay.
Consequently, we hold that petitioner is liable for a $5,000
penalty pursuant to section 6673(a)(1).
To reflect the foregoing,
An appropriate order of
dismissal and decision will be
entered for respondent.
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