- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10Last modified: November 10, 2007