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the taxpayer primarily for delay or that the taxpayer’s position
in such proceeding is frivolous or groundless. Although we shall
not impose a penalty upon petitioner pursuant to section 6673, we
nevertheless take this opportunity to admonish petitioner that
the Court will consider imposing such a penalty should he return
to the Court and advance similar arguments in the future.
To reflect the foregoing,
An order of dismissal and
decision will be entered.
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Last modified: May 25, 2011