- 30 - grounds of respondent’s determinations of deficiencies. We find petitioner is deserving of a significant penalty because of the persistence of her frivolous assault. On our own motion, pursuant to section 6673(a)(1), we will require petitioner to pay a penalty to the United States in the amount of $5,000. Decision will be entered under Rule 155.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30
Last modified: May 25, 2011