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times by respondent and the Court that her arguments were
frivolous and without merit, and that if she continued to advance
them she could be subject to a penalty of up to $25,000. Even
after receiving these repeated warnings, petitioner continued to
advance the same 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 $2,500
penalty.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011