- 4 - 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011