- 28 - caution her that she may be subject to such a penalty if in the future she institutes or maintains a proceeding in the Court primarily for delay and/or her position in any such proceeding is frivolous or groundless. See Abrams v. Commissioner, 82 T.C. 403, 409-413 (1984); White v. Commissioner, 72 T.C. 1126, 1135- 1136 (1979). We have considered all of the contentions and arguments of Ms. Latos that are not discussed herein, and we find them to be without merit, irrelevant, and/or moot. To reflect the foregoing, Decision will be entered for respondent in the case at docket No. 16522-02L and an appropriate decision will be entered for respondent in the case at docket No. 5829-06L.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28Last modified: November 10, 2007