- 25 - 10765-00 and 10766-00 asking the Court to impose a penalty under section 6673(a)(1) on petitioner in each of those cases, the Court found in Richards I that petitioner instituted the proceed- ings in each of those cases primarily for delay and that his position in each such case was frivolous and/or groundless. We held in Richards I that petitioner was liable for a penalty under section 6673(a)(1) in the case at docket No. 10765-00 in the amount of $8,000 and in the case at docket No. 10766-00 in the amount of $18,000. Pursuant to Richards I, on March 28, 2002, the Court entered an Order of Dismissal and Decision in each of the cases at docket Nos. 10765-00 and 10766-00. In each such Order, the Court granted respondent’s motion to dismiss for lack of prosecution in each such case in that we dismissed each of those cases for failure by petitioner to prosecute. The Court also entered in each such Order a decision in each of the cases at docket Nos. 10765-00 and 10766-00 (1) sustaining the determinations that respondent made in the notice of deficiency to which each such case pertained, but in reduced amounts which respondent conceded were appropriate in order to reflect the duplication of certain income determinations in the respective notices of deficiency issued to Mr. Richards, and (2) imposing a penalty pursuant to section 6673(a)(1) on Mr. Richards in the case at docket No. 10765-00 in the amount of $8,000 and in the case at docket No.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011