- 11 -
Although we shall not impose a penalty on petitioner pursuant to
section 6673(a)(1) in the present case, we admonish petitioner
that the Court will consider imposing such a penalty should he
return to the Court in the future and advance similar arguments.
To reflect the foregoing,
An order and decision will
be entered granting respondent’s
motion for summary judgment.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011