Stephanie K. Mills - Page 10




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          egregious in wasting both the Court's and respondent's time and             
          resources.  Other positions advanced by petitioner were                     
          groundless, such as her claim that the notice of deficiency was             
          invalid due to respondent's failure to prepare a return under               
          section 6020(b), see Geiselman v. United States, 961 F.2d 1, 5              
          (1st Cir. 1992); Schiff v. United States, 919 F.2d 830, 831 (2d             
          Cir. 1990); Brenner v. Commissioner, T.C. Memo. 2004-202, affd.             
          164 Fed. Appx. 848 (11th Cir. 2006), and her claim of a lack of             
          an evidentiary foundation for respondent's income determination.            
          Accordingly, we shall impose a penalty on petitioner under                  
          section 6673(a)(1) in the full amount sought by respondent;                 
          namely, $5,000.                                                             
               To reflect the foregoing,                                              

                                             An appropriate order and                 
                                        decision will be entered.                     





















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