Stephanie K. Mills - Page 10
- 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;
To reflect the foregoing,
An appropriate order and
decision will be entered.
Page: 1 2 3 4 5 6 7 8 9 10
Last modified: November 10, 2007