- 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