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future he institutes or maintains a proceeding in this Court
primarily for delay and/or his position in any such proceeding is
frivolous or groundless. See Abrams v. Commissioner, 82 T.C.
403, 409-413 (1984); White v. Commissioner, 72 T.C. 1126, 1135-
1136 (1979).
We have considered all of the parties’ contentions and
arguments that are not discussed herein, and we find them to be
without merit and/or irrelevant.
On the record before us, we shall grant respondent’s motion.
To reflect the foregoing,
An order granting respondent’s
motion and decision will be entered
for respondent.
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