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As discussed above, we found in the Court’s February 6, 2007
Order that the petition contained statements, contentions, and
arguments that are frivolous and groundless. Although we shall
not impose a penalty under section 6673(a)(1) on petitioner in
the instant case, we caution him that he may be subject to such a
penalty if in the 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. Commis-
sioner, 82 T.C. 403, 409-413 (1984); White v. Commissioner, 72
T.C. 1126, 1135-1136 (1979).
We have considered all of petitioner’s statements, conten-
tions, and arguments that are not discussed herein, and, to the
extent we have not found them to be frivolous and groundless, we
find them to be without merit and/or irrelevant.
To reflect the foregoing,
An order granting respondent’s
motion and decision for respondent
will be entered.
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Last modified: November 10, 2007