Paula M. Olsen - Page 8

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          to pay tax deficiencies over a tax shelter that she viewed as               
          fraudulent.  Her actions in not filing proper tax returns were              
          nothing more than acts of civil disobedience.  Her pleadings, as            
          noted above, were frivolous and consumed the time and efforts of            
          this Court.  Moreover, her testimony to the Court that the only             
          relief she sought was the recusal of respondent's attorney                  
          evinced an intent to delay this proceeding and its ultimate                 
          conclusion.  The Court holds that petitioner is liable for the              
          penalty under section 6673 and imposes such penalty in the amount           
          of $750.                                                                    
               Because of respondent's concessions,                                   

          Decision will be entered                                                    
          under Rule 155.                                                             

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