Bruce M. Crow - Page 6

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          against petitioner in the amounts set forth in the notice of                
          deficiency, and consider imposing a penalty against petitioner              
          under section 6673.  Respondent's Motion for Summary Judgment was           
          continued for further hearing to August 16, 1995, in Washington,            
          On August 8, 1995, petitioner filed a second amended                        
          petition which in large part repeats and expands upon the                   
          arguments found in both his amended petition and his reply to               
          respondent's answer.  Among his various contentions, petitioner             
          alleged that respondent erred in determining that petitioner                
          earned nonemployee compensation for the years in issue on the               
          ground that the compensation in question was paid in the form of            
          corporate stock subject to section 83.  Petitioner also alleged             
          that respondent erred in determining that he failed to report               
          unearned income for the years in issue.  In particular,                     
          petitioner asserted that the notes and contracts of sale that are           
          the subject of this adjustment were not sold as respondent                  
          determined but, rather, were the subject of a "like kind                    
          exchange" with an individual identified as James Shinault.                  
               This case was again called for hearing in Washington, D.C.,            
          on August 16, 1995.  Counsel for respondent appeared at the                 
          hearing and presented further argument in support of the pending            
          motion.  Petitioner did not appear at the hearing.                          

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