- 14 -
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
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011