- 13 -
In the present case, we shall give petitioner the benefit of
the doubt and not impose a penalty under section 6673.
Nevertheless, we admonish petitioner that the Court will consider
imposing such a penalty should she return to the Court in the
future and advance frivolous or groundless arguments or institute
or maintain an action primarily for delay.
In order to give effect to the foregoing,
An order and decision will be
entered granting respondent's motion for
summary judgment and denying
respondent's request for the imposition
of a penalty under section 6673(a).
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011