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frivolous or groundless. Respondent has not asked that we impose
a section 6673 penalty. We strongly warn petitioners that they
may be subject to section 6673 penalties, even upon the Court’s
own motion, if they continue to press frivolous arguments in this
Court.
To reflect the foregoing and respondent’s concession,
Decisions will be entered
under Rule 155.
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Last modified: November 10, 2007