Sue Taylor - Page 37

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         Respondent sought a section 6673 penalty in respondent’s pretrial            
         memorandum, but respondent did not request a penalty during trial            
         or on brief, and the Court declines to impose such a penalty                 
         today.  However, the Court explicitly admonishes petitioner that             
         she may, in the future, be subject to a penalty under section                
         6673 for any further proceedings instituted or maintained                    
         primarily for delay or for any proceedings which are frivolous or            
         groundless.                                                                  
              The Court has considered all of petitioner’s contentions,               
         arguments, requests, and statements.  To the extent not discussed            
         herein, we have found them to be meritless, irrelevant, or moot.             
              To reflect the foregoing and concessions made by respondent,            

                                                 Decision will be entered             
                                            under Rule 155.                           

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