- 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 28
Last modified: November 10, 2007