Mildred I. Criss, et al. - Page 20




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               On the record before us, we find that Ms. Criss instituted             
          the proceedings in the case at docket No. 9700-00 primarily for             
          delay.  We also find on that record that Ms. Criss’ position in             
          the case at docket No. 9700-00 was frivolous and/or groundless.             
          On the record before us, we shall impose a penalty on Ms. Criss             
          pursuant to section 6673(a)(1) in the amount of $3,000.                     
               On the record before us, we find that Mr. Criss instituted             
          the proceedings in the case at docket No. 9701-00 primarily for             
          delay.  We also find on that record that Mr. Criss’ position in             
          the case at docket No. 9701-00 was frivolous and/or groundless.             
          On the record before us, we shall impose a penalty on Mr. Criss             
          pursuant to section 6673(a)(1) in the amount of $20,000.                    
               To reflect the foregoing,                                              

                                             An appropriate order of dis-             
                                        missal for lack of jurisdiction and           
                                        denying respondent’s motion will be           
                                        entered in the case at docket No.             
                                        9702-00, and an appropriate order             
                                        granting respondent’s motion and              
                                        decision will be entered in each of           
                                        the cases at docket Nos. 9700-00              
                                        and 9701-00 sustaining respondent’s           
                                        determinations and imposing a pen-            
                                        alty under section 6673(a)(1) in              
                                        each of those two cases.                      




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