Jeffrey S. and Susan L. Duffield - Page 5

                                        - 5 -                                         
               Respondent contends that petitioners’ position is frivolous            
          and instituted primarily for delay and that, pursuant to section            
          6673(a)(1), the Court should impose a penalty on petitioners.  We           
          decline, however, to impose such a penalty in this case.                    
               Contentions we have not addressed are irrelevant, moot, or             
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                

Page:  Previous  1  2  3  4  5  

Last modified: May 25, 2011