-12-
future, he is at risk that the Court is likely to impose such a
penalty, up to $25,000.
We sustain respondent’s determinations in the deficiency
notice. We have considered all remaining arguments the parties
made and, to the extent not addressed, we conclude they are
irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: November 10, 2007