- 4 - 1996, respondent filed her response. Respondent contends that her calculations account for the investment tax credit sought by petitioner. Discussion Petitioner argues that the decision document prepared by respondent fails properly to reflect an investment tax credit. Respondent has satisfied the Court, however, that the decision document properly reflects the particular adjustment sought by petitioner. In light of petitioner's scant response to respondent's motion for entry of decision, we agree with respondent. The record indicates that respondent provided petitioner with two proposed decision documents. Respondent concedes that the first of these decision documents failed to account for the credit sought by petitioner. The record indicates, however, that the second decision document properly accounts for the subject credit. Respondent requests that the Court impose against petitioner and his counsel a penalty pursuant to section 6673(a)(1) and (2). In support of this request, respondent contends that petitioner advanced arguments primarily for the purpose of delaying entry of decision. In the exercise of our discretion, we shall not grant respondent's request. To reflect the foregoing, An appropriate order will be issued granting respondent's motion for entry of decision, and decision will be entered accordingly.Page: Previous 1 2 3 4
Last modified: May 25, 2011