John S. Cooper, Jr. - Page 2

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          an addition to tax under sec. 6651(a)(2).  In his petition,                 
          petitioner questioned the entire deficiency, alleging that                  
          respondent was in error and more specifically that respondent’s             
          agent had no authority to conduct an examination and that                   
          petitioner was not afforded due process2 during the                         
          administrative examination procedures.  Respondent has orally               
          moved that the Court award sanctions under section 6673, alleging           
          that petitioner’s position is frivolous and interposed merely for           
          delay.  We consider the following issues in this opinion:  (1)              
          Whether petitioner has shown that respondent’s determination is             
          in error, and (2) whether petitioner is liable for the additions            
          to tax under sections 6651(a)(1), 6651(a)(2), and 6654(a); and              
          (3) whether damages should be awarded under section 6673.                   

















               2 Petitioner has not made clear how he was not afforded “due           
          process” or what he means by that term.                                     





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