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section 6330(c)(1) and demonstrates that petitioners were issued
notices and demands for payment on the same dates that respondent
entered the assessments in question. Finally, respondent argued
that petitioners’ behavior warranted the imposition of a penalty
under section 6673. Respondent subsequently filed an amendment
to his motion for summary judgment correcting a citation therein.
Petitioners filed an objection to respondent’s motion.
Thereafter, pursuant to notice, respondent’s motion was called
for hearing at the Court’s motions session in Washington, D.C.
Counsel for respondent appeared at the hearing and offered
argument in support of respondent’s motion. In lieu of appearing
at the hearing, petitioners filed a written statement with the
Court pursuant to Rule 50(c).
Following the hearing, the Court directed respondent to file
a further amendment to his motion addressing the question whether
respondent’s determination of additions to tax under section
6654, as set forth in the notice of deficiency dated March 27,
1996, and subsequently assessed, was correct. Respondent filed a
second amendment to his motion conceding that he had erroneously
determined and improperly assessed additions to tax under section
6654 in the amounts of $708, $954, and $1,092, for the taxable
years 1992, 1993, and 1994, respectively.3 Transcripts of
3 The addition to tax under sec. 6654, which is imposed
when an individual taxpayer fails to pay estimated tax, is
(continued...)
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