BELOT, District Judge.
This is an appeal from a decision of the United States Tax Court affirming income tax deficiencies with attendant penalties and fines assessed by the Commissioner, and imposing an additional penalty under 26 U.S.C. § 6673 for the pursuit of frivolous or groundless litigation. For the reasons stated below, we dismiss the appeal for lack of jurisdiction, see generally Wagoner v. Wagoner,
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