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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.
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Last modified: May 25, 2011