Patricia R. Carpentier - Page 11

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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           
          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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