- -4 of cases. Respondent stated that since claims comparable to those made by petitioner had been rejected by this Court and other courts that this case be decided in her favor on the pleadings. In the motion respondent also requests the Court to award damages to the United States in an appropriate amount under section 6673. By order dated August 9, 1995, petitioner was given until September 8, 1995, to reply to respondent's motion for judgment on the pleadings. In the order giving petitioner until September 8, 1995, to respond to respondent's motion, the Court pointed out that this Court and other courts had rejected arguments similar to petitioner's arguments, and that if petitioner responded without satisfactorily showing any distinction between the allegations he now makes and those uniformly rejected by this and other courts as frivolous, respondent's motion would be granted and the deficiencies and additions to tax as set forth in the notice of deficiency would be determined against petitioner. The order directed petitioner to file an amended petition, if he contended there were any factual errors in respondent's computation of his tax liability for any year here in issue. The order also directed petitioner to state the reasons, if any, why this Court should not award damages to the United States under section 6673 based on the fact that this case was instituted primarily for delay and that petitioner's position in the case is frivolous or groundless.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011