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2 One must also [take] into consideration that most of
those individuals referred to as “CONGRESSMEN,” that
[sic] if they can be identified at all by the
respondent, are more then likely DEAD or not referred
to as “CONGRESSMEN” and [sic] longer. Are petitioners
subject to the written will of individuals who are
dead?
Ms. Sluyter signed the motions for reconsideration. We denied
them.
Trial Session
These cases came on for hearing (the hearing), pursuant to
notice, at the trial session. At the hearing, respondent moved
to amend the motions for judgment on the pleadings to limit them
to the deficiencies in each case (and exclude the penalties).
Counsel for petitioners stated that she had no objection to those
motions, and the Court granted them. The Court took the motions
for judgment on the pleadings, as amended (still, motions for
judgment on the pleadings), under advisement. Respondent also
informed the Court that he would be making a motion for partial
summary judgment with respect to the penalties determined by him
in each case. The Court gave respondent leave until July 5,
2000, to make such motion and allowed petitioners until August 4,
2000, to respond.
The Court did not conduct proceedings on those portions of
the April 24 order ordering (1) petitioners to show cause why
they should not be subject to a penalty under section 6673(a)(1)
and (2) Ms. Sluyter to show cause why she should not be required
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