Richards Asset Mgmt. Trust, et al. - Page 25




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          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.              






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