- 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 meritless. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011