- 12 - comply with the Court's Order directing the filing of a proper second amended petition. Considering all of the circumstances, we will exercise our discretion under section 6673(a)(1) and require petitioner to pay a penalty to the United States in the amount of $2,500. Coleman v. Commissioner, supra at 71-72; Crain v. Commissioner, supra at 1417-1418; Abrams v. Commissioner, supra at 408-411. To reflect the foregoing, An order and decision will be entered granting respondent's Motion for Summary Judgment and imposing a penalty upon petitioner pursuant to section 6673(a)(1).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011