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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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