- 12 - prepare this opinion, spending time and effort that would have been better spent on a good faith controversy requiring resolution of claims having colorable merit. We therefore exercise our discretion under section 6673(a)(1)(A) and (B), and impose upon and require petitioner to pay a penalty of $15,000 to the United States. To give effect to the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011