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law and unsupported by a reasoned, colorable argument for change
in the law.’” Williams v. Commissioner, 114 T.C. 136, 144 (2000)
(quoting Coleman v. Commissioner, 791 F.2d 68, 71 (7th Cir.
1986)).
Respondent, by motion, has asked the Court to impose a
penalty under section 6673(a)(1). Because some of the issues
raised by petitioner, including his entitlement to dependency
exemptions, education credits/a deduction for tuition and fees,
and a moving expense deduction were not frivolous, we afford
petitioner the benefit of the doubt and do not impose a penalty
under section 6673(a)(1). Petitioner is warned, however, that
the Court may not be so inclined should he return to the Court
and advance arguments as groundless as some of the other
arguments advanced in this case.
The Court has considered all of petitioner’s contentions,
arguments, requests, and statements. To the extent not discussed
herein, we conclude that they are meritless, moot, or irrelevant.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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