William J. Brumback - Page 9




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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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