Brenda J. Gammon - Page 8

                                        - 8 -                                         


               In order to reflect the foregoing,                                     


                                             An order of dismissal and                
                                        decision will be entered.                     


























          pursuant to sec. 6673(a).  In the exercise of our discretion,               
          however, we decline to award a penalty in this case.                        
          Nevertheless, petitioner is advised that sec. 6673(a)(1)                    
          authorizes the Tax Court to require a taxpayer to pay to the                
          United States a penalty not in excess of $25,000 whenever it                
          appears that proceedings have been instituted or maintained by              
          the taxpayer primarily for delay or that the taxpayer's position            
          in such proceeding is frivolous or groundless.                              




Page:  Previous  1  2  3  4  5  6  7  8  

Last modified: May 25, 2011