Charles P. Dewitt - Page 4

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          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.                                                    

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