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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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Last modified: May 25, 2011