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litigant, generally refrained from urging those arguments in his
post-trial memorandum. Moreover, respondent has conceded error
in the notice of deficiency with respect to the employment tax
determinations. Therefore, we decline to impose a penalty in
this case, and respondent's oral motion will be denied. In so
doing, we caution petitioner that future assertions of such
groundless arguments will result in substantial penalties
pursuant to section 6673.
To reflect respondent's concessions,
An appropriate order
and decision will be entered.
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Last modified: May 25, 2011