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respondent and the Court that his arguments were frivolous and
without merit, and that if he continued to advance them he could
be subject to a penalty of up to $25,000. Even after receiving
these repeated warnings, petitioner continued to advance
frivolous and meritless arguments.
We conclude petitioner’s position was frivolous and
groundless and that petitioner instituted and maintained these
proceedings primarily for delay. Accordingly, pursuant to
section 6673(a) we hold petitioner is liable for a $5,000
penalty.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: November 10, 2007