PER CURIAM:
Thomas W. Roberts appeals the Tax Court's grant of partial summary judgment in favor of the Commissioner of Internal Revenue ("Commissioner") on his petition challenging a tax assessment. He also challenges the assessment of a $10,000.00 penalty for maintaining this action for delay. Because the Tax Court: (1) correctly determined that the appeals officer verified the existence of the assessment, and (2) did not abuse its discretion in imposing sanctions...
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