OPINION
HALPERN, Judge:
This case is before the Court to consider whether petitioner must pay a penalty pursuant to section 6673(a)(1) and whether petitioner's counsel, Paul J. Sulla, Jr. (Mr. Sulla), must pay certain of respondent's costs pursuant to section 6673(a)(2). For the reasons that follow, the Court shall impose on petitioner a penalty of $15,000 and on Mr. Sulla a liability of $10,500.
Unless otherwise indicated, all section references...
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