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Cir. 1978)(citations omitted).
In that regard, petitioner has been given every opportunity
to litigate the merits of respondent’s determination which was
issued on November 6, 1995. This case, at petitioner’s request,
has been moved to several different trial cities and placed on
numerous trial sessions only to have petitioner seek a
continuance. In all that time, petitioner has done little to
develop the case or resolve the issues underlying the income tax
deficiencies. At this point, petitioner no longer objects to the
entry of a decision for the reduced income tax liabilities
proposed by respondent. Petitioner, however, does not agree to
the additions to tax and penalties but has not shown reasonable
cause as to why she should not be held liable for failure to file
returns and/or to pay estimated tax. As indicated in footnote 4
of this opinion, we have already held that petitioner is liable
for the additions to tax.
Accordingly, respondent’s Motion to Dismiss, filed on
December 26, 2000, and respondent’s Supplemental Motion to
Dismiss filed on April 6, 2001, will be granted and a decision
for the reduced amounts of income tax deficiencies and additions
to tax under sections 6651(a)(1) and 6654 will be entered against
petitioner.
B. Respondent’s Motion for Damages Under I.R.C. Section 6673
Under section 6673(a) a taxpayer may be required to pay the
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