John N. Sweeney - Page 8

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          reply to respondent’s answer, and in his response to respondent’s           
          motion for summary judgment.  Accordingly, we shall impose a                
          $10,000 penalty on petitioner pursuant to section 6673.                     
               To reflect the foregoing,                                              

                                            An appropriate order and                  
                                       decision will be entered.                      


































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