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HEIM v. C.I.R.

Nos. 88-1633 to 88-1635.

872 F.2d 245 (1989)

Laura HEIM, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Clarence HEIM, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee. Elmer HEIM, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Decided April 10, 1989.

Attorney(s) appearing for the Case

David R. Brennan, Minneapolis, Minn., for appellants.

Janet A. Bradley, Washington, D.C., for appellees.

Before LAY, Chief Judge, JOHN R. GIBSON, Circuit Judge, and NICHOL, Senior District Judge.

JOHN R. GIBSON, Circuit Judge.

Laura, Clarence and Elmer Heim appeal from a decision of the tax court denying leave to file motions to vacate an earlier tax court decision, which determined there were deficiencies in their federal gift taxes and imposed penalties. The Heims contend that the tax court had authority to vacate its earlier decision and should have done so because of the gross negligence of their attorney in conducting...

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