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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.
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Last modified: May 25, 2011