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advancing had been universally rejected by the courts that have
considered them.
Petitioner’s positions, based on stale and meritless
contentions, are manifestly frivolous and groundless. This has
caused the Court to waste limited resources. Accordingly, we
shall impose a penalty of $5,000 pursuant to section 6673.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: November 10, 2007