Robert Ho - Page 14

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          6651(a)(3)” and respondent’s assertion in his motion for summary            
          judgment, as supplemented, the Court issued an Order dated                  
          December 15, 2005, directing the parties to supplement their                
          respective motions in certain respects by January 13, 2006.                 
          Specifically, the Court directed respondent to state the basis on           
          which he assessed the addition to tax under section 6651(a)(2)              
          when such addition was never determined in the notice of                    
          deficiency, nor summarily assessed pursuant to sections 6020(b)             
          and 6651(g)(2).  The Court also directed petitioner to provide a            
          precise interest computation that mathematically demonstrates the           
          basis for his allegation that respondent did not correctly                  
          compute the interest assessed, to clearly specify the applicable            
          interest rate, the period of time to which each rate is                     
          applicable, and the principal amount against which the interest             
          rate is applied.                                                            
               Petitioner did not file a supplement as directed in the                
          Court’s December 15, 2005 Order.                                            
          Second Supplement To Respondent’s Motion For Summary Judgment               
               On January 13, 2006, respondent filed a Second Supplement To           
          Respondent’s Motion For Summary Judgment.  In the second                    
          supplement, respondent conceded that the addition to tax under              
          section 6651(a)(2) may not be assessed and collected from                   
          petitioner for taxable year 2001.  Respondent further stated that           
          he would abate the previously assessed addition to tax under                






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