Alex B. Rhodes, Jr. - Page 14




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               In Rhodes v. Commissioner, T.C. Memo. 2003-133, the Tax                
          Court imposed a penalty of $2,000 on petitioner pursuant to                 
          section 6673(a)(1) because petitioner had advanced frivolous                
          arguments.  Before trial in the instant case, the Court warned              
          petitioner on seven occasions that it would impose a penalty                
          under section 6673(a)(1) if he continued to advance frivolous               
          arguments.  At trial, the Court also warned petitioner on                   
          numerous occasions that if he continued to advance frivolous                
          arguments, it would impose a penalty under section 6673(a)(1).              
               Despite the warnings of the Court, petitioner continued to             
          assert groundless arguments.  Under the circumstances, the Court            
          will, on its own motion, impose a penalty of $15,000 on                     
          petitioner pursuant to section 6673(a)(1).                                  
               In reaching our holdings, we have considered all arguments             
          made, and, to the extent not mentioned, we conclude that they are           
          moot, irrelevant, or without merit.                                         
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             under Rule 155.                          














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