Todd B. Guthrie - Page 4

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          a section 6651(a)(2) addition to tax.  Thus, it would be                    
          inappropriate to impose a section 6673 penalty.  Nevertheless, we           
          admonish petitioner that he may be subject to a section 6673                
          penalty if he asserts frivolous or groundless contentions in a              
          subsequent proceeding in this Court.                                        
               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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