- 5 -
Respondent contends that petitioner’s position is frivolous
and instituted primarily for delay and that, pursuant to section
6673(a)(1), the Court should impose a penalty on petitioner. 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.
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Last modified: May 25, 2011